On Wednesday, July 23, 2025, the White House released the “America’s AI Action Plan” (the “AI Action Plan”). The AI Action Plan is the result of the Trump Administration’s Request for Information, which describes policy actions related to artificial intelligence as it seeks to replace the Biden Administration’s “AI Diffusion Rule.” The
Export Control Compliance
Client Alert: New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions
By Carlton Greene, Dj Wolff, Jeremy Iloulian & Kelsey Clinton on
Posted in Export Administration Regulations (EAR)
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.
Click here to continue reading the full version of this alert.
BIS Issues “Best Practices” Guidance for Mitigating Export Diversion Risk
By Edward Goetz on
Posted in Supply Chain
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…
Pressure Rising: New U.S. and UK Sanctions and Export Controls Increase Risks for Lingering Russia Exposure, Indirect Evasion in the Supply Chain, and IT Support for Russia Operations
Posted in Russia Sanctions
An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.
Click here to continue reading the full version of this alert.
Aid and Sanctions: Ukraine, Israel, and Taiwan Aid Bill Expands U.S. Sanctions and Export Control Authorities
Posted in Sanctions, Ukraine, Israel, and Taiwan Aid
The latest U.S. foreign aid bill supporting Ukraine, Israel, and Taiwan enacted on April 24, 2024 enhances U.S. sanctions and export controls including expanding (1) the statute of limitations for sanctions violations; (2) the President’s authority to coordinate sanctions efforts with the European Union and the United Kingdom; (3) sanctions and export controls on Iran…
BIS and DDTC Amendments Add Nicaragua to EAR Country Group D and ITAR § 126.1
By Crowell & Moring on
Posted in Export Controls
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…
Commerce, Treasury, DOJ Publish Tri-Seal Sanctions and Export Control Compliance Note
Posted in Sanctions
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…