On February 26, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) reached an administrative enforcement settlement with Teledyne FLIR LLC and its affiliates FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems, Inc. d/b/a Teledyne FLIR OEM, (together, “Teledyne FLIR”), imposing a $1,000,000 civil penalty to resolve alleged violations
BIS Fines Exyte $1.5 Million for Unlicensed Transfers to China’s SMIC
On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $1.5 million civil penalty on Exyte Management GmbH (“Exyte”), a Germany- headquartered engineering and procurement company, after its Shanghai affiliate Exyte Shanghai Ltd., (“Exyte China”) admitted to illegally causing the transfer of approximately $2.8 million in EAR-subject semiconductor…
China Announces New Export Controls Targeting Japan
On January 6, 2026, China’s Ministry of Commerce (“MOFCOM”) issued Announcement No. 1 [2026], imposing export controls on dual-use items destined for Japan. The measures took effect immediately, with no wind-down period.
Under the announcement, exports of all dual-use items from China are prohibited where the end user or end use: (i) involves Japanese…
China Expands Rare Earth Export Controls and Adds 14 Entities to the Unreliable Entity List
On Thursday, October 9, 2025, China issued a series of new export control measures and designations on China’s Unreliable Entity List (UEL).
The new controls significantly expand the scope of China’s oversight over its rare earth materials by comprehensively regulating the entire supply chain of Chinese-origin rare earths, from specified raw materials to mining and…
U.S. Department of Commerce Rescinds Biden Administration’s AI Diffusion Export Control Rule and Issues New Guidance on Huawei, Chips for AI Purposes, and Diligence Expectations
- Key takeaway #1The new guidance amounts to prohibitions on U.S. and non-U.S. persons using, selling, transferring, financing, or servicing Huawei’s Ascend 910B, 910C, and 910D chips, as well as other comparable chips from other Chinese companies.
- Key takeaway #2While the U.S. Department of Commerce Bureau of Industry and Security (BIS) has issued some advanced computing-related
Global Trade Talks: Tariff Relief: Update on the U.S. – China Tariffs
Considering the impact of U.S. – China tariffs on our economy and the global supply chain, Nicole Simonian and Dj Wolff, Co-Chairs of the International Trade Group, talk with Alex Schaefer, International Trade partner, as he helps us understand the details and impact of the recent U.S. – China tariffs deal, as well as what…
The Maximum Pressure Campaign Escalates: OFAC Designates a Chinese Refiner of Iranian Crude
On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated the “teapot” Chinese oil refinery Shandong Shouguang Luqing Petrochemical Co., Ltd. (“Luqing Petrochemical”), its chief executive officer, eight vessels, and eleven vessel owners, managers, and operators, on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”).
USTR Announces Final Decisions on Section 301 Tariffs
The Office of the United States Trade Representative (“USTR”) today published a Federal Register notice announcing its final modifications to its Four-Year Statutory Review of U.S. Section 301 tariffs on a range of Chinese-origin goods. While the USTR declined to modify its proposed increase of additional duties on electric vehicles (to 100 percent in 2024)…
USTR Issues Request for Comment on Proposed Section 301 Changes, Extends Exclusions
The Office of the United States Trade Representative (“USTR”) today published a request for comments on the proposed modifications and machinery exclusion process in its Four-Year Review of Section 301 tariffs (the “Review”), published last week. The Review did not recommend removing any subheadings from Section 301 tariffs, but rather proposed the following increases:
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Biden Administration Proposes New Section 301 Tariffs
This week, President Biden has directed the United States Trade Representative (“USTR”) to take further action against Chinese unfair trading practices following the release of the statutory four-year review of Section 301 tariffs against the People’s Republic of China (“PRC”). Per Biden’s direction, Ambassador Katherine Tai announced that she will be proposing modifications to existing…