On March 12th, the Office of the United States Trade Representative (USTR) initiated investigations under Section 301(b) of the Trade Act of 1974 of 60 countries for potential forced labor violations resulting in unfair competition for US companies selling abroad. According to U.S. Trade Representative Jameison Greer, the investigations will examine whether these
Jeffrey L. Snyder
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.
China Announces New Export Controls Targeting Japan
On January 6, 2026, China’s Ministry of Commerce (“MOFCOM”) issued Announcement No. 1 [2026], imposing export controls on dual-use items destined for Japan. The measures took effect immediately, with no wind-down period.
Under the announcement, exports of all dual-use items from China are prohibited where the end user or end use: (i) involves Japanese…
U.S. and China Announce Temporary Suspension of Certain Tariffs and Export Controls Following Trump–Xi Meeting in South Korea
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…
China Expands Rare Earth Export Controls and Adds 14 Entities to the Unreliable Entity List
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…
SNAP-R Legacy Site to be Decommissioned June 30, Migrating to New Platform
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…
U.S. Department of Commerce Rescinds Biden Administration’s AI Diffusion Export Control Rule and Issues New Guidance on Huawei, Chips for AI Purposes, and Diligence Expectations
- 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
BIS Rescinds Biden Administration’s AI Diffusion Export Control Rule
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…
DOJ Declines Prosecution of Company for Employee’s Unlawful Export
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)…
DHS Adds Five Companies to UFLPA Entity List
- Kashgar Construction Engineering (Group) Co., Ltd.;
- Xinjiang Habahe Ashele Copper Co., Ltd. (also known as Ashele Copper);
- Xinjiang Tengxiang Magnesium Products Co., Ltd.;
- Century Sunshine Group Holdings,
BIS Announces Further Updates to OEE’s Voluntary Self-Disclosure Process for Minor Violations
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…