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Since 1986, Jeff's practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of U.S. extraterritorial regulations. Jeff assists companies in day-to-day compliance with these laws, and with interventions — such as audits and investigations, and civil enforcement proceedings.

On October 30, 2025, President Trump and Chinese President Xi Jinping met in Busan, South Korea – this marks the first time the two leaders have engaged in face-to-face talks since 2019, during Trump’s first term.

According to a statement from China’s Ministry of Commerce (MOFCOM) issued during a press briefing following the meeting, the

On Thursday, October 9, 2025, China issued a series of new export control measures and designations on China’s Unreliable Entity List (UEL).

The new controls significantly expand the scope of China’s oversight over its rare earth materials by comprehensively regulating the entire supply chain of Chinese-origin rare earths, from specified raw materials to mining and

The current version of SNAP-R will be decommissioned on June 30, 2025, and a new SNAP-R site and URL (https://snapr.bis.gov/) is taking its place. All current users should migrate their SNAP-R accounts from the decommissioned site to the new platform for continued access. Each user’s account must be migrated individually, and it is

  • Key takeaway #1The new guidance amounts to prohibitions on U.S. and non-U.S. persons using, selling, transferring, financing, or servicing Huawei’s Ascend 910B, 910C, and 910D chips, as well as other comparable chips from other Chinese companies.
  • Key takeaway #2While the U.S. Department of Commerce Bureau of Industry and Security (BIS) has issued some advanced computing-related

The Bureau of Industry and Security (BIS) announced plans on May 13,2025, to rescind the Biden Administration’s AI diffusion export control rule, which was set to take effect on May 15. BIS will issue a formal rescission notice in the Federal Register and plans to introduce a replacement rule in the future. BIS enforcement officials

On April 30, 2025, the U.S. Department of Justice (DOJ) announced it would not prosecute the Universities Space Research Association (USRA) for alleged violations of the Export Administration Regulations (EAR). This marks the DOJ’s second declination in the last twelve months under the National Security Division’s (NSD) Enforcement Policy for Business Organizations (NSD VSD Policy)

On January 16, 2024, Bureau of Industry and Security (BIS) Assistant Secretary for Export Enforcement Matthew Axelrod announced further updates to the EAR voluntary self-disclosure (VSD) process, all designed to incentivize the prioritization of export control compliance resources of the U.S. Government, industry, and academia.

The Office of Export Enforcement (OEE) released a Memorandum to

On December 11, the U.S. Department of Treasury (“Treasury”)’s Office of Foreign Assets Control (“OFAC”) announced sanctions against two former Afghan government officials, Mir Rahman Rahmani and his son, Ajmal Rahmani (collectively, “the Rahmanis”), as well as 44 associated entities. These individuals and entities were designated pursuant to Executive Order 13818, which builds upon and

On December 8, the Department of Homeland Security (“DHS”) announced the addition of three People’s Republic of China (“PRC”)-based companies to the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List as part of the ongoing effort to eliminate forced labor practices in U.S. supply chains. The addition of these three entities—COFCO Sugar Holding Co. Ltd