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On July 10, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released guidance to provide helpful “best practices” for companies and universities who have received a “supplier list” letters, Project Guardian requests, “red flag” letters, or “is informed” letters from BIS.

These notifications generally require the recipients of the letter to take…

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…

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…

On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and…

The U.S. Department of Commerce, Bureau of Industry and Security (BIS), published a final rule on February 23, 2024, amending the Export Administration Regulations (EAR) by revising license requirements for certain cameras, systems, and related components to eliminate license requirements for certain cameras to Country Group A:1. In addition to these changes, BIS is adding…

Feb. 23, 2024–Today, following the death of opposition politician and anti-corruption activist Aleksey Navalny, and after two years of Russia’s unprovoked and unlawful full-scale invasion of Ukraine, the Commerce Department’s Bureau of Industry and Security (BIS) imposed additional export restrictions on 93 entities under 95 entries in Russia and seven other destinations. Sixty-three of the…

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…