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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…

What You Need to Know

  • Key takeaway #2 Failure to initiate an internal investigation promptly after discovering a potential export controls or sanctions
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    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…

    Russia Sanctions: This week the United States designated dozens of additional entities and individuals as Specially Designated Nationals (“SDNs”).  Notable designations included State Corporation Rostec (“Rostec”), a large Russian state-owned company that operates in the automotive, defense, aviation, and metal industries; individuals who were part of a covert procurement network linked to Russia’s Federal…