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

Chandler Leonard
Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.
FinCEN and the U.S. Department of Commerce Issue Joint Alert Highlighting Risks of Export Control Violations for Financial Institutions
On June 28, 2022, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert (the “Alert”), urging financial institutions regulated under the Bank Secrecy Act (“BSA”) to remain vigilant of efforts by third parties to evade the extensive U.S. export controls imposed on…
Update: Expanded U.S. Ban on Russian Imports and Russia’s Removal from Permanent Normal Trade Relations Status
President Joseph Biden formally announced via Executive Order that the following Russian-origin goods will no longer be permitted importation into the U.S. customs territory:
- Fish, seafood, and preparations thereof;
- Alcoholic beverages;
- Non-industrial diamonds; and
- Any other products of Russian Federation-origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary
…
Breaking News: Expanded U.S. Ban on Russian Imports and Russia’s Removal from Permanent Normal Trade Relations Status
Friday, March 11, 2022 – Today, United States President Joseph Biden formally announced via Executive Order that the following Russian-origin goods will no longer be permitted importation into the U.S. customs territory:
- Fish, seafood, and preparations thereof;
- Alcoholic beverages;
- Non-industrial diamonds; and
- Any other products of Russian Federation-origin as may be determined by the Secretary
…
UPDATE: [Close of Comments on Commerce Cyber Rule] Jan.20.2022
On January 12, 2022 the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a federal register notice delaying the effective date of new controls on cybersecurity items and an accompanying new license exception. The rules are now set to take effect on March 7, 2022.
The new controls were published in an …
BIS and DDTC Add Cambodia to their ‘Naughty’ List
On December 9, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) both issued final rules adding export restrictions on Cambodia.
BIS amended the Export Administration Regulations (EAR) to implement more restrictive export controls for Cambodia to ensure that items…
DDTC Adds Ethiopia to List of Proscribed Countries and Updates Restrictions applied to Eritrea.
On November 1, 2021, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a final rule adding Ethiopia to the Proscribed Country List found in the International Traffic in Arms Regulations (ITAR) in § 126.1 and also updating the existing restrictions on Eritrea.
A policy of denial now applies to licenses (or…
Bureau of Industry and Security Issues Proposed Rule to Amend Export Administration Regulations to Clarify and Expand Restriction on the Availability of License Exception Strategic Trade Authorization
On October 22, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced its proposal to amend the Export Administration Regulations (EAR) in order to clarify and expand restrictions on the availability of License Exception Strategic Trade Authorization (License Exception STA or STA) for items controlled by the EAR. BIS proposed clarifying…
BIS Announces $469,060 Settlement Agreement with California-based Semiconductor Company For Conspiracy Involving exports to Two Entity Listed Chinese Companies
On August 16, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) that it had reached a settlement agreement with Dynatex International (“Dynatex” or “the company”) – a California-based semiconductor company – where the company would pay a civil penalty of $469,060 for allegedly violating the Export Administration Regulations (EAR).
In its…
Commerce Adds 23 Companies to Entity List Citing Forced-Labor, Military Technology, and Sanctions Concerns
On July 9, 2021, The Department of Commerce (DOC) determined that 23 Chinese companies took actions contrary to the foreign policy interests of the United States and were added to the Entities List. The Bureau of Industry and Security (BIS) noted that it “publishes the names of certain foreign persons – including businesses, research institutions,…