On September 12, 2024, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a final rule to amend the Export Administration Regulations (EAR) revising provisions related to the voluntary self-disclosure (VSD) process for persons who believe that they may have violated the EAR, or any order, license or authorization issued thereunder. The
OFAC Extends Recordkeeping Requirements from 5 to 10 Years Through Interim Final Rule
On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it is seeking comments on a new interim final rule amending OFAC’s Reporting, Procedures and Penalties Regulations to extend recordkeeping requirements from five to ten years. While OFAC is seeking comments within 30 days, the interim final rule
OFAC, State Department, and BIS Expand Russian/Belarusian Sanctions
On August 23rd, 2024, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State (State), and the Commerce Department’s Bureau of Industry and Security (BIS) acted against Russia’s international supply chains.
OFAC and State collectively sanctioned nearly 400 individuals and entities. Of note, this included a substantial focus on
DHS Adds Five Companies to UFLPA Entity List
On August 8, 2024, the U.S. Department of Homeland Security (DHS) added five companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.
The companies are:
USTR Postpones Implementation of New Section 301 Tariffs
On July 30, 2024, the Office of the U.S. Trade Representative (USTR) announced the increased Section 301 tariffs proposed on May 28, 2024, would not go into effect as planned on August 1, 2024.
USTR is still reviewing the 1,100 public comments it received. It now expects its final determination will be issued sometime in
BIS Issues “Best Practices” Guidance for Mitigating Export Diversion Risk
On July 10, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released guidance to provide helpful “best practices” for companies and universities who have received a “supplier list” letters, Project Guardian requests, “red flag” letters, or “is informed” letters from BIS.
These notifications generally require the recipients of the letter to take
OFAC Sanctions Shadow Banking Network for Iran Military
On June 25, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 50 entities and individuals comprising an expansive “shadow banking” network used by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and Islamic Revolutionary Guard Corps (IRGC) to gain access to the international financial system, and added
Growing Technology Supply Chain Risks: Kaspersky Lab Software Banned in First Use of ICTS Supply Chain Prohibition
On June 20, 2024, the U.S. Department of Commerce Bureau of Industry and Security announced its first Final Determination pursuant to the Securing the Information and Communications Technology and Services Supply Chain (ICTS) regulations, prohibiting Kaspersky Lab, Inc. from providing anti-virus software and cybersecurity products or services in the United States or to U.S. persons
BIS Amends Licensing Requirements of Certain Cameras and Camera Systems
The U.S. Department of Commerce, Bureau of Industry and Security (BIS), published a final rule on February 23, 2024, amending the Export Administration Regulations (EAR) by revising license requirements for certain cameras, systems, and related components to eliminate license requirements for certain cameras to Country Group A:1. In addition to these changes, BIS is adding
OFAC Updates Civil Monetary Penalties
Last week, OFAC announced it is increasing its maximum amount of the civil monetary penalties (CMP) that may be assessed under relevant OFAC regulations by implementing the Federal Civil Penalties Inflation Adjustment Act of 1990 for 2024. These increases adjust for inflation and have occurred nine times since 2015. The changes to the CMPs are