Trade law and supply chain news, insights, and commentary
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 29, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published a series of Frequently Asked Questions (FAQs) addressing comments received on the October 13, 2022 interim final rules that amended, and in some cases expanded, U.S. export restrictions on semiconductor manufacturing items and advanced computing items and end uses. …
On December 19, the Bureau of Industry and Security (“BIS”) added 13 new entities to its Unverified List (“UVL”). All 13 of these entities were added under the destination of the Peoples’ Republic of China (“PRC”) on the basis that BIS was unable to verify their bona fides.
The UVL contains the names and addresses…
On August 28, 2023, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) proposed new rules to streamline and strengthen the Section 232 Exclusions Process for Steel and Aluminum imports. The proposed rules will build on the five existing interim final rules and respond to public comments received by BIS since February 2022. BIS…
On June 28, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security issued a press release reporting formal cooperation amongst the Five Eyes Intelligence Oversight and Review Council (“Five Eyes”) to expand enforcement of export controls. Five Eyes—an intelligence alliance between Australia, Canada, New Zealand, the United Kingdom, and United States—formalized its cooperation…
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 March 28th, BIS issued a final rule amending the Export Administration Regulations (EAR) to confirm that protecting human rights worldwide is a basis for adding entities to the Entity List. Additionally, BIS added 11 entities from Burma, China, Nicaragua, and Russia to the Entity List.
As reflected in the decision by the…
On February 24, 2023, the United States and other G7 nations announced a number of new sanctions and export control measures coinciding with the one-year mark of Russia’s military invasion of Ukraine. Shortly after these expansive sanctions and export controls were announced, the Departments of Justice (“DOJ”), the Treasury (“Treasury”), and Commerce (“Commerce”) issued their…
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…
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