Photo of 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.

Russia Sanctions:  The U.S., EU, and UK continue to apply pressure on Russia through new sanctions on oligarchs and politicians and restrictions on exports.  A number of other countries have implemented similar measures and continue to widen the scope of such prohibitions as the invasion continues.  On a more limited scale, Belarus has also

On February 3, 2021, U.S. Senators Josh Hawley (R-MO) and Kirsten Gillibrand (D-NY) introduced the Slave-Free Business Certification Act of 2022. The bipartisan bill would require companies that have an annual, worldwide receipts that exceeds $500 million and that are involved in the mining, production, or manufacture of goods for sale to conduct an audit

On February 8, 2022, The Bureau of Industry and Security (BIS) amended  the Export Administration Regulations (EAR) by adding Wuxi Biologics, one of the most valuable Chinese biotechnology companies, and thirty-two other organizations to the Unverified List (UVL).

In the accompanying BIS press release, Matthew S. Axelrod, Assistant Secretary for Export Enforcement, noted that

On February 7, 2022, the United States and Japan issued a joint statement announcing a 232 tariff agreement allowing historically-based sustainable volumes of Japanese steel products to enter the U.S. market without tariffs.

An overview of the actions as provided by the Department of Commerce is provided below:

The United States will replace the existing

Comment Period for UFLPA Opens on January 24

As an update to our Uyghur Forced Labor Prevention Act (“UFLPA”) post, the public comment period will open on Monday, January 24, 2022.  A Federal Register Notice will be published on Monday and the 45-day comment period will end on March 10, 2022.  The UFLPA was

Thea Rozman Kendler and Matthew Axelrod joined the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) as Assistant Secretaries of Commerce. Both were nominated by President Biden and confirmed by the Senate.

Under the Export Control Reform Act, 50 U.S.C. §4852(a), the President must appoint two Assistant Secretaries of Commerce to assist the

This is an update to our December 22, 2021 post on the Uyghur Forced Labor Prevention Act.

On December 23, 2021, President Joe Biden signed into law the Uyghur Forced Labor Prevention Act (UFLPA). This action by President Biden comes a week after the law passed both chambers of Congress. After stalling in the Senate

On December 16, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) added eight Chinese entities to its Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) list for “actively support[ing] the biometric surveillance and tracking of ethnic and religious minorities in China, particularly the predominantly Muslim Uyghur minority in Xinjiang.” As such, U.S. persons

On December 9, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) both issued final rules adding export restrictions on Cambodia.

BIS amended the Export Administration Regulations (EAR) to implement more restrictive export controls for Cambodia to ensure that items

On November 1, 2021, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a final rule adding Ethiopia to the Proscribed Country List found in the International Traffic in Arms Regulations (ITAR) in § 126.1 and also updating the existing restrictions on Eritrea.

A policy of denial now applies to licenses (or