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On November 14, 2025, President Trump signed an executive order modifying the scope of reciprocal tariffs originally imposed under Executive Order 14257 of April 2, 2025, which declared a national emergency based on large and persistent U.S. goods trade deficits. The November 14 order exempts certain agricultural products from the reciprocal tariff regime, effective for…

In new guidance published on October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued recommendations about its expectations for financial institutions in complying with U.S. export control obligations.

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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 September 28, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), alongside the UK, Australia, Canada, New Zealand (termed the “Export Enforcement Five” or “E5,”), as well as the EU, issued new guidance with recommended best practices to help prevent a list of “high-priority items” from being diverted to Russia. 

These…