On February 7, 2025, Representative Mark Green (R-TN-7) introduced the China Technology Transfer Control Act, a bill which would restrict the export to the People’s Republic of China (“PRC”) certain “national interest technology” and intellectual property. According to a statement by Rep. Green, the bill is intended as a sign to “get serious about protecting
Export Controls
Trump Sets Stage for Future Tariffs and Trade Actions
On his first day in office, President Trump rolled out a sprawling set of directives to the heads of numerous government agencies charged with shaping U.S. trade policy. While stopping short of enacting new tariffs, the Presidential Memorandum defining an “America First Trade Policy” lays the investigative groundwork for potentially sweeping changes to tariffs and…
Commerce Releases ANPRM to Bolster Drone Supply Chain Security
On January 2, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM) soliciting public input on securing the supply chain for unmanned aircraft systems (UAS). BIS seeks to address supply chain risks posed by the involvement of foreign adversaries in UAS-related information and communication…
BIS Amends Voluntary Self-Disclosure Process and Penalty Guidelines and Adds First-Ever Chief of Corporate Enforcement
On September 12, 2024, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a final rule to amend the Export Administration Regulations (EAR) revising provisions related to the voluntary self-disclosure (VSD) process for persons who believe that they may have violated the EAR, or any order, license or authorization issued thereunder. The…
ITAR and EAR Proposed Rules Expand Controls on U.S. Person Services
On July 25, 2024, the U.S. Departments of State and Commerce issued new proposed rules that, if implemented, would (1) increase the restrictions associated with U.S. persons providing services in support of non-U.S. military-related end users / uses; and (2) implement new controls associated with exports, reexports, and transfers of items subject to the EAR…
Global Trade Talks – Expanded U.S. Sanctions and Export Control Authorities Included in the Ukraine, Israel, and Taiwan Aid Bills
In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers Jeremy Iloulian and Laurel Saito about the significant new sanctions and export control authorities included in the recently enacted National Security Supplemental fiscal package. While this legislation is best known for providing U.S. foreign aid commitments for…
BIS Streamlines Export Controls for Transfers to and Among Australia and the UK
By Chandler Leonard on
On April 19, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to enhance technological innovation and support the goals of the AUKUS trilateral security partnership.
The interim final rule makes six primary export control policy changes that effectively provide Australia and the UK nearly the same…
New U.S. Sanctions and Export Controls Imposed on Iran Following Recent Attacks on Israel
By Jeremy Iloulian on
On Thursday, April 18, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new sanctions on Iran following its April 13, 2024 attack on Israel. OFAC designated 16 individuals and ten entities as Specially Designated Nationals and Blocked Persons (SDN), specifically those involved in Iran’s unmanned aerial vehicle (UAV), steel, and…
BIS Updates Rules on Advanced Semiconductors
By Chandler Leonard & Andrew J. Schlegel on
Posted in Export Controls
The Department of Commerce’s (“DOC”) Bureau of Industry and Security (“BIS”) has published an interim final rule, as well as a request for comments, regarding new export controls for advanced computer, supercomputer, semiconductor, and manufacturing items. This update to the interim final rule serves to correct inadvertent errors and clarify export licensing procedures outlined in…
BIS and DDTC Amendments Add Nicaragua to EAR Country Group D and ITAR § 126.1
By Crowell & Moring on
Posted in Export Controls
On March 15, 2024, the Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) amended the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) to implement new restrictions on trade with Nicaragua.
BIS’s amendments moved Nicaragua from Country Group B to Country Group D, applying a…