The Department of Commerce’s Bureau of Industry and Security (“BIS”) announced today new export controls and Entity List additions designed to further restrict Russia’s ability to maintain its continued war
Continue Reading BIS Issues New Export Controls and Entity List Additions Targeting Russia on One-Year Anniversary of Invasion
OFAC Issues Sweeping Sanctions to Mark One-Year Anniversary of Russia’s Invasion of Ukraine
On Friday, February 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new sanctions against individuals and entities operating in Russia and against those assisting with
Continue Reading OFAC Issues Sweeping Sanctions to Mark One-Year Anniversary of Russia’s Invasion of UkraineExport Control Violations Result in Significant Monetary Penalties and Continuing Compliance Training Obligations
In a recent order, the Department of Commerce’s Bureau of Industry and Security (“BIS”) revoked the export privileges for Obaidullah Sayed, an Illinois resident. Sayed was convicted of conspiring
Continue Reading Export Control Violations Result in Significant Monetary Penalties and Continuing Compliance Training ObligationsBiden Administration No Longer Approving Export Licenses to Chinese Tech Giant Huawei
According to recent reports, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has stopped granting export licenses to Huawei Technologies Co. Ltd. (“Huawei”).
The U.S. government has
Continue Reading Biden Administration No Longer Approving Export Licenses to Chinese Tech Giant HuaweiBIS Adds 35 Chinese Entities to Entity List for Supporting China’s Military Modernization Efforts and Nine Russian Entities for Failure to Complete Satisfactory End-Use Checks
On December 16, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule adding 35 entities from China and one entity from Japan to the Entity
Continue Reading BIS Adds 35 Chinese Entities to Entity List for Supporting China’s Military Modernization Efforts and Nine Russian Entities for Failure to Complete Satisfactory End-Use ChecksOFAC Continues to Take Aim at Russia’s Financial Sector with More SDN Designations
On December 15, 2022, the Office of Foreign Assets Control (“OFAC”) added 18 entities in Russia’s financial services sector to the Specially Designated Nationals and Blocked Persons List (“SDN List”).
Continue Reading OFAC Continues to Take Aim at Russia’s Financial Sector with More SDN DesignationsBIS Adds 24 New Entities and Removes One from Entity List and Extends Deadline for Comments to New Semiconductor Rules
BIS Adds 24 New Entities and Removes One from Entity List
On December 8, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a notice in the
Continue Reading BIS Adds 24 New Entities and Removes One from Entity List and Extends Deadline for Comments to New Semiconductor RulesU.S. Departments of Treasury and State Expand Sanctions To Restrict Russia’s Access to Services and Economics and Combat Evasion and Backfill Activities
On June 28, 2022, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Joint Alert urging financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s further invasion of Ukraine. After providing an overview of recent BIS actions in response to Russia’s invasion of Ukraine, the Joint Alert identifies commodities that present “special concern because of their potential diversion to and end use by Russia and Belarus to further their military and defense capabilities,” all of which require a BIS license prior to export or reexport to Russia and Belarus.
Continue Reading U.S. Departments of Treasury and State Expand Sanctions To Restrict Russia’s Access to Services and Economics and Combat Evasion and Backfill Activities
OFAC and State Department Designate Severstal, Nord Gold and Additional Russians as SDNs
On June 2, 2022, the Office of Foreign Assets Control (OFAC) added new Russian vessels and aircraft used by Russian elites, new top Russian government officials, and their companies and operations to the Specially Designated Nationals (SDN) List for aiding in the continued war effort by Russia against Ukraine. Notably, these designations include more Russian government officials and oligarchs, and two of the largest mining companies in Russia, Severstal PJSC (Severstal) and Nord Gold PLC (Nord Gold). This means that U.S. persons cannot engage in any transactions with Severstal or Nord Gold unless authorized by a license.
Continue Reading OFAC and State Department Designate Severstal, Nord Gold and Additional Russians as SDNs
BIS Adds 71 Entities to Entity List; Issues Russia/Belarus Corrections and Clarifications; and Updates EAR to Allow Immediate Publication of Charging Letters
On June 2, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) updated the Export Administration Regulations (“EAR”) to: (i) add 71 entities to the Entity List “for acquiring or attempting to acquire U.S.-origin items in support of Russia’s military”; (ii) issue minor revisions, corrections, and clarifications to its Russia and Belarus export controls; and (iii) increase its administrative disclosure authorities to allow the publication of charging letters prior to a resolution of an administrative case. The changes went into effect immediately on June 2, 2022 and were published in the Federal Register on June 6, 2022 via two Final Rules available (here) and (here).
Continue Reading BIS Adds 71 Entities to Entity List; Issues Russia/Belarus Corrections and Clarifications; and Updates EAR to Allow Immediate Publication of Charging Letters
BIS Considers More Public and Expensive Consequences for Companies Violating the EAR
Matthew Axelrod, the Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), told a conference held by the Society for International Affairs on May 16, 2022, that his agency is considering major policy changes to its administrative enforcement authorities. Axelrod said the policy changes, expected to be rolled out in the next few months, are intended to incentivize export compliance by corporations under the Export Administration Regulations (“EAR”).
Continue Reading BIS Considers More Public and Expensive Consequences for Companies Violating the EAR