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On April 19, 2021, the Office of Foreign Assets Control (“OFAC”) issued Belarus General License 2H (“GL 2H”) revoking General License 2G (“GL 2G”), which was due to expire on April 25, 2021.

For more than five years, OFAC regularly extended GL 2 G, and earlier versions of it, authorizing U.S. person activity with the

On April 8, the Bureau of Industry and Security (BIS) issued a final rule that added the following seven Chinese entities to the Entity List:

  • National Supercomputing Center Jinan
  • National Supercomputing Center Shenzhen
  • National Supercomputing Center Wuxi
  • National Supercomputer Center Zhengzhou
  • Shanghai High-Performance Integrated Circuit Design Center
  • Sunway Microelectronics
  • Tianjin Phytium Information Technology

The entities

On April 15, 2021, the United States unveiled a sweeping series of additional sanctions on Russia, marking the first major Russia-related sanctions development of the Biden Administration and the most material such U.S. action in several years.  The actions were spearheaded by President Biden’s issuance of an as-yet-unnumbered Executive Order (the “EO”) that grants the

On January 15, 2021, in the final days of the Trump Administration, BIS published an Interim Final Rule, Expansion of Certain End-Use and End-User Controls and Controls on Specific Activities of U.S. Persons, also referred to as the Military Intelligence End User rule (“MIEU Rule”). It was set to be effective March 16, 2021

On March 5, 2021, U.S. Customs and Border Protection (CBP) denied Dandong Huayang’s protest, which asserted that North Korean nationals did not produce  garments that were imported under two separate entries. CBP determined that the materials submitted by the protestant did not establish clear and convincing evidence that Dandong Huayang did not use North Korean

In an update to our prior post published on March 8, the Bureau of Industry and Security (BIS) and State Department published additional actions against Russia in response to the poisoning of Aleksey Navalny on March 18. The new sanctions and export controls are summarized below.

Bureau of Industry and Security

The Secretary of

On March 29, 2021, U.S. Customs and Border Protection (CBP) is scheduled to publish a Notice of Finding that certain disposable gloves produced by Top Glove Corporation Bhd (Top Glove) in Malaysia are made with forced labor. Section 307 of the Tariff Act of 1930 prohibits the importation of goods “mined, produced, or manufactured wholly

During a recent panel at Georgetown Law’s annual International Trade Update, two Federal Circuit judges urged trade attorneys to consider their audience and simplify their briefs. Although the U.S. Court of International Trade is specialized, Federal Circuit Judge Todd M. Hughes emphasized how the conversation must change when a trade matter is appealed to the