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
Department of Commerce
BIS Amends Licensing Requirements of Certain Cameras and Camera Systems
By Edward Goetz on
Posted in Export Administration Regulations (EAR)
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…
BIS/OFAC Announce New Sanctions and Entity List Designations on Two-Year Anniversary of Russia’s Invasion of Ukraine
By Andrew J. Schlegel on
Posted in Russia Sanctions
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…
U.S. Department of Commerce Joins with Allied and Partner Countries to Recommend Best Practices, Including Specific End User Assurances, To Prevent Diversion of 45 High Priority Items to Russia
By Jeremy Iloulian on
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…
Final Rule from Commerce on National Security Guardrails for CHIPS Act Funding: Restrictions on China and Other Countries of Concern
By Jeremy Iloulian on
- Key takeaway #1 Specific Guardrails Subject to Negotiation: The Final Rule indicates that more of the national security guardrails will be negotiated with the recipient, creating the opportunity for project specific agreements.
- Key takeaway #2 Broader than the EAR: The CHIPS Act national security guardrails have some overlap with U.S.
Comment Window Closes for Proposed Commerce Antidumping and Countervailing Duty Rules: Foreign Governments, Trade Associations, and Companies Weigh in on Contentious Changes
The comment window for the Department of Commerce’s (“the Department”) proposed rules for Antidumping and Countervailing Duty (“ADCVD”) Regulations closed on July 10, 2023. Pursuant to its authority under Title VII of the Tariff Act of 1930, the Department proposed to amend its regulations to strengthen its enforcement of trade remedies by revising many of its…