Photo of Jeffrey L. Snyder

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

On November 16, the U.S. signed a major multilateral supply chain agreement with its 13 Indo-Pacific Economic Framework for Prosperity (IPEF) partners – Australia, Brunei, Fiji, India, Indonesia, Japan, Republic of Korea, Malaysia, New Zealand, Philippines, Singapore, Thailand, and Vietnam. As highlighted in the IPEF joint statement, the 14 countries announced the signature of

From September 30, 2023, new EU and UK sanctions will come into effect targeting the imports of specified iron and steel products which are processed in third countries and incorporate Russian-origin iron and steel inputs. Importers will need to declare upon import whether the imported goods are compliant (and be prepared to provide evidence demonstrating

Last Friday, the U.S. Departments of Commerce, Justice, State, and the Treasury issued a joint guidance sheet on Iran’s unmanned aerial vehicles (“UAVs”) program (the “Iran UAV Guidance”). The Iran UAV Guidance highlighted (I) the threat Iran’s UAV program poses; (II) the key items that Iran relies on to expand its UAV program; (III) the

On April 18, 2023, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) released a memorandum entitled, “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning Others” (the “April Memo”).  The April Memo highlights additional penalties and incentives to encourage exporters – and whistleblowers – to disclose potential violations of the

On Friday, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued its latest set of export controls in response to Russia’s invasion of Ukraine. The broadest expansion of U.S. export controls on Russia since last fall, Friday’s actions are separate and distinct from the new sanctions regulations imposed by the U.S. Department