Export Administration Regulations (EAR)

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UK Publishes General License for Energy for Mongolia: On August 16, 2022, the UK published General License INT/2022/2085212 for Mongolia energy payments.  The license permits payments to the Credit Bank of Moscow, Gazprombank, Sberbank, Rosbank PJSC, or any entity owned or controlled by these banks, for the purpose of making energy available for use…

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 October 22, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced its proposal to amend the Export Administration Regulations (EAR) in order to clarify and expand restrictions on the availability of License Exception Strategic Trade Authorization (License Exception STA or STA) for items controlled by the EAR. BIS proposed clarifying…

On July 19, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) added six Russian entities to the Entity List for their relation to the Russian government’s “harmful foreign activities” that present a threat to the United States’ national security, foreign policy, and economy. Specifically, the entities were added to the Entity List…

On July 9, 2021, The Department of Commerce (DOC) determined that 23 Chinese companies took actions contrary to the foreign policy interests of the United States and were added to the Entities List. The Bureau of Industry and Security (BIS) noted that it “publishes the names of certain foreign persons – including businesses, research institutions,…

On July 2, 2021, the Bureau of Industry and Security (BIS) added four more Burmese entities to the Entity List for their relation to the Burmese military and its February coup. In doing so, BIS limits the four entities’ ability to access commodities, software, and technology subject to the Export Administration Regulations (EAR).

One of…

On June 28, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Settlement Agreement with Patriot 3 Inc. – a Virginia-based military equipment company – for $200,000 after the BIS alleged that Patriot 3 violated Section 764.2(e) of the Export Administration Regulations (EAR). Specifically, BIS alleged that on October 2014, 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 9, 2021, BIS issued an interim final rule to make corrections and changes to its January 15, 2021 interim final rule establishing new end-use and end-user controls with respect to certain military-intelligence end uses and end users.

Our prior updates on these restrictions can be found here and here.

In addition to…

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…