On December 5th, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued new Compliance Program Guidelines (CPG) intended to provide an overview of an effective compliance program.

The CPG is broken down into elements covering the spectrum of ITAR compliance from company management commitment, registration, jurisdiction and classifications, authorizations, recordkeeping, violations

On October 20, 2022, the Committee on Foreign Investment in the U.S. (CFIUS) adopted long-awaited CFIUS Enforcement and Penalty Guidelines (the “Guidelines”) identifying how it will review and consider three categories of non-compliances that may be subject to penalties:

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Two new rules announced by the U.S. Department of Commerce, Bureau of Industry and Security (BIS) strive to severely inhibit China’s progress in indigenously producing advanced semiconductors. Although advanced semiconductors are widely used for commercial applications, BIS cited serious concerns regarding China’s use of the technology for WMD and military applications, and enabling human rights

On September 15, 2022, the Biden Administration issued a new executive order (“EO”) and accompanying fact sheet, designed to sharpen the current U.S. foreign investment screening process as administered by the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”).[1]  This EO is the first to specifically identify certain additional

On April 8, the Bureau of Industry and Security (BIS) issued a final rule that added the following seven Chinese entities to the Entity List:

  • National Supercomputing Center Jinan
  • National Supercomputing Center Shenzhen
  • National Supercomputing Center Wuxi
  • National Supercomputer Center Zhengzhou
  • Shanghai High-Performance Integrated Circuit Design Center
  • Sunway Microelectronics
  • Tianjin Phytium Information Technology

The entities

In an update to our prior alert published last month, the Bureau of Industry and Security (BIS) has taken several additional actions further restricting Myanmar (Burma)’s access to items subject to the Export Administration Regulations (EAR).  Last month, BIS publicly stated it was considering additional export control restrictions and as predicted, on March 4, 2021,

On March 2, 2021, the Biden Administration announced the intelligence community’s finding that Russia’s Federal Security Service (FSB) used a banned chemical nerve agent to poison Russian opposition leader, Aleksey Navalny.  Shortly following the White House’s press briefing, the Departments of State, Commerce, and Treasury issued press releases announcing new sanctions and export controls, summarized

On December 23, the Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to remove the People’s Republic of China (PRC or China) Special Administrative Region of Hong Kong from the list of destinations in the EAR.  The amendment implements Sections 2 and 3 of Executive Order 13936 of July 14, 2020,

BIS remains busy during the closing days of the year. On December 18 and 21 the Department of Commerce issued several press releases announcing the addition of 77 entities to the Entity List, and for the first time, a Military End User List. The December 18 press releases (here and here) announced the

On October 17, BIS issued a press release announcing that exporters may request a six-month extension for any licenses due to expire on or before December 31, 2020.

The press release states, “BIS will streamline the extension of the validity process by creating a central electronic mailbox for submission of requests: LicenseExtensionRequest@bis.doc.gov.” The original