Trade law and supply chain news, insights, and commentary
On April 25, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule that added 18 new persons and removed five persons from the Unverified List (UVL).
Of the 18 persons added in the UVL, five are located in China, six are located in Finland, three are located in…
On April 9, 2025, President Trump signed and released an Executive Order (EO) to “improve speed and accountability” in the U.S. defense trade system and published an accompanying fact sheet. The EO identifies specific actions for executive branch agencies to take including: (i) reverting back to the Conventional Arms Transfer Policy that President Trump…
On January 3, 2025, President Biden issued a National Security Memorandum (NSM) to update policy guidance for the Government of the United States’ implementation of the Missile Technology Control Regime (MTCR). The NSM directs the relevant executive branch agencies to provide increased flexibility for case-by-case review and facilitate support for certain MTCR Category I military…
On January 9, 2025, DDTC’s new registration fee rates become effective. This is the first time in fifteen years DDTC has increased the registration fees charged to those who are required to register with DDTC pursuant to the Arms Export Control Act. Pursuant to the final rule amending parts 122 and 129 of the ITAR…
On August 20, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an interim final rule to 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). The interim final rule implements the proposed rule DDTC published…
On March 15, 2024, the Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) amended the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) to implement new restrictions on trade with Nicaragua.
BIS’s amendments moved Nicaragua from Country Group B to Country Group D, applying a…
On September 28, 2023, the Cyberspace Administration of China published the draft Provisions on Regulating and Promoting Cross-Border Data Flows (“Draft Provisions”) for public consultation, demonstrating that China is trying to strike a balance between enhancing data security and promoting data-driven economic growth. Multinational companies with cross-border data transfers involving China are recommended to revisit…
On July 25, 2023, the Senate overwhelmingly approved a measure to add mandatory notifications of certain investments in China to the National Defense Authorization Act (“NDAA”). The Outbound Investment Transparency Act, authored by Senators John Cornyn (R-TX) and Bob Casey (D-PA), would require U.S. companies to notify the government of investments in certain Chinese sectors…
On March 28th, BIS issued a final rule amending the Export Administration Regulations (EAR) to confirm that protecting human rights worldwide is a basis for adding entities to the Entity List. Additionally, BIS added 11 entities from Burma, China, Nicaragua, and Russia to the Entity List.
As reflected in the decision by the…
In ruling N326984 (August 2, 2022), Customs and Border Protection (CBP) discussed the tariff classification of torrefied wood pellets from Vietnam. The pellets under consideration consist of agglomerated, powdered wood by-products – which include sawdust, sawmill waste, wood manufacturing waste, and tree waste. The powdered wood is agglomerated under heat and pressure. The pelletized material…
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