On July 25, 2024, the U.S. Departments of State and Commerce issued new proposed rules that, if implemented, would (1) increase the restrictions associated with U.S. persons providing services in support of non-U.S. military-related end users / uses; and (2) implement new controls associated with exports, reexports, and transfers of items subject to the EAR

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.
DDTC Publishes Proposed ITAR Amendments to Enhance AUKUS Defense Trade
On May 1, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a proposed rule that, if implemented, would streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership).
CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance
The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has published proposed regulatory amendments that, if implemented, would expand CFIUS’s authority to seek information for non-notified transactions, establish timelines for parties to respond to CFIUS’s mitigation proposals, and increase penalties for certain violations to the greater of $5 million or the…
BIS Streamlines Export Controls for Transfers to and Among Australia and the UK
On April 19, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to enhance technological innovation and support the goals of the AUKUS trilateral security partnership.
The interim final rule makes six primary export control policy changes that effectively provide Australia and the UK nearly the same…
BIS Updates Rules on Advanced Semiconductors
The Department of Commerce’s (“DOC”) Bureau of Industry and Security (“BIS”) has published an interim final rule, as well as a request for comments, regarding new export controls for advanced computer, supercomputer, semiconductor, and manufacturing items. This update to the interim final rule serves to correct inadvertent errors and clarify export licensing procedures outlined in…
Commerce, Treasury, DOJ Publish Tri-Seal Sanctions and Export Control Compliance Note
On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and…
Pressure Mounting: United States and United Kingdom Impose New Sanctions and Export Controls on Russia
Following a meeting of the G7 Summit Leaders, on May 19, 2023, the United States and the United Kingdom announced a new round of sanctions and export controls against the Government of the Russian Federation (“Russia”) to continue their efforts against key sectors of Russia’s military-industrial base.
Proposed Rule Requires Certain Contractors to Provide Export Authorizations to DCMA
On March 22, 2023, the Department of Defense (DoD) issued a proposed rule that would amend the Defense Federal Acquisition Regulation Supplement (DFARS) to require certain contractors to provide export authorizations to the Defense Authorization Management Agency (DCMA).
DCMA performs quality assurance reviews for manufacturing operations to ensure contractors have the appropriate systems in place…
New U.S. Restrictions on Transfers to China for Semiconductor and Advanced Computing Uses
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…
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…