On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) simultaneously published a final rule strengthening the antiboycott regulations in Part 766 of the Export Administration Regulations (EAR) (the “Final Rule”), as well as a memorandum on the new rule’s implementation (the “Final Rule Memo”), issued by the Assistant Secretary for Enforcement. Pursuant to the Final Rule, BIS will make three primary changes:

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Photo of Edward Goetz Edward Goetz

Edward Goetz is the manager for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control…

Edward Goetz is the manager for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control, economic sanctions, anti-money laundering (AML), anti-corruption/anti-bribery, and antiboycott. He has extensive government experience providing information and interpretive guidance on the International Traffic in Arms Regulations (ITAR) concerning the export of defense articles, defense services, and related technical data. He also assists attorneys with matters involving the Export Administration Regulations (EAR), economic sanctions, AML, anti-corruption/anti-bribery, and trade remedies.

Photo of Jeremy Iloulian Jeremy Iloulian

Jeremy Iloulian is an associate in Crowell & Moring’s Chicago office and is a member of the International Trade Group. Jeremy advises clients globally on complex cross-border investigative, regulatory, compliance, and transactional matters and policy developments that touch U.S. national security, international trade…

Jeremy Iloulian is an associate in Crowell & Moring’s Chicago office and is a member of the International Trade Group. Jeremy advises clients globally on complex cross-border investigative, regulatory, compliance, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls, economic sanctions, anti-boycott laws, and the Committee on Foreign Investment in the United States (CFIUS).

Photo of Rachel Schumacher Rachel Schumacher

Rachel Schumacher is an associate in the International Trade and Government Contracts groups in Crowell & Moring’s Washington, D.C. office. Rachel’s practice focuses on transactions, investigations, and compliance and advisory matters involving a variety of government contracts and international trade issues.