On June 4, 2026, Crowell Partners Caroline Brown and Anand Sithian hosted the ACSS New York Chapter at the New York office for an in-person panel discussion titled “Renewed Focus on Cartels, Transnational Criminal Organizations, and Foreign Terrorist Organizations: Compliance Challenges for Financial Institutions and Multinationals.” The sold-out event brought together practitioners from the
BIS Confirms Advanced Chip License Requirements Extend to D:5 and Macau-Headquartered Entities Worldwide
Key Takeaway: BIS’s latest guidance closes an ambiguity created by the AI Diffusion Rule rollback, confirming that the original 2023 license requirement for advanced computing items exported to Country Group D:5 and Macau-headquartered entities remains in full force – regardless of where those entities are physically located.
On May 31, 2026, the U.S. Department of…
Firewall Up: FCC Bars Foreign-Made Routers in New Covered List Update
On March 23, 2026, the Federal Communications Commission (FCC) updated its Covered List—a list of communications equipment and services deemed to pose an unacceptable risk to U.S. national security or the safety and security of U.S. persons—to include consumer-grade routers produced in a foreign country, absent an exemption granted by the U.S. Departments of…
BIS Fines Teledyne FLIR $1 Million for Unlicensed China-Related Thermal Camera Exports and De Minimis Miscalculations
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”).