Export Controls & Economic Sanctions

As part of the U.S. Government’s ongoing response to the military coup in Burma (Myanmar), the Department of Commerce’s Bureau of Industry and Security (“BIS”) added four entities to the
Continue Reading US Government Adds 4 Military-Connected Entities in Burma to Entity List and Sanctions 22 Burmese Individuals

Earlier this month, the US Government updated its ongoing response to what the Department of Commerce (“Commerce”) described as “Beijing’s campaign of repression, mass detention, and high-technology surveillance against Uyghurs,
Continue Reading U.S. Adds Chinese Entities to BIS Entity List and Updates Xinjiang Supply Chain Business Advisory

The Biden Administration has taken new actions related to forced labor in the Xinjiang region that may affect the supply for material critical for solar panels: U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO), the Department of Commerce (Commerce) updated its Entity List, and the Department of Labor (Labor) updated its “List of Goods Produced by Child Labor or Forced Labor.”  These updates are part of an increased emphasis on both forced labor issues and a crackdown on goods from China’s Xinjiang province, and come on the heels of the G7 Summit that was held in mid-June.  The White House indicated that the Administration’s actions are a “translation” of the commitments made at the G7 denouncing forced labor in the Xinjiang region.
Continue Reading Biden Administration’s Recent Actions Related to Products from China’s Xinjiang Region

On January 23, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of State issued two final rules, available here and here
Continue Reading After 9th Circuit Mandate BIS Formally Assumes Jurisdiction Over 3D Printed Firearms Technology and Software

Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned various individuals and entities connected to Russia’s technology sector and also expanded sanctions against dealings in Russian sovereign
Continue Reading Biden Administration Imposes New Russia Sanctions and Establishes Framework for Future Expansion of Russian Sanctions Regime

The Department of Defense (“DoD”) requested industry comments by April 28, 2021 to assist with the DoD’s forthcoming report identifying risks and policy recommendations regarding the supply chain for strategic
Continue Reading DoD Requests Comments on Supply Chain Risks for Strategic and Critical Materials

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued final rules amending the Export Administration Regulations (“EAR”) by implementing new export controls on Burma (Myanmar), and adding
Continue Reading BIS Implements New Burma Export Controls and Adds Four Entities to the Entity List

The merging of Hong Kong with China with respect to Hong Kong’s treatment under the Export Administration Regulations (“EAR”) is now reflected in the Department of Commerce’s Bureau of Industry and Security’s Hong Kong recordkeeping guidance.  On February 19, 2021, BIS updated its Hong Kong recordkeeping FAQs to make that guidance consistent with the final rule BIS issued on December 23, 2020 implementing Executive Order 13936 (the “E.O.”).  The E.O. was signed in the wake of U.S. objections to Chinese government national security legislation imposed on Hong Kong in 2020, which outlaws any act of “secession,” “terrorism,” or “collusion” with a foreign power.
Continue Reading BIS Updates Hong Kong Recordkeeping FAQs Consistent with Removal of Hong Kong from EAR Country Chart

On February 1, 2021, the military of Burma (Myanmar) in an unanticipated coup d’état installed General Min Aung Hlaing as leader and detained the country’s top elected leaders, including the
Continue Reading U.S. Imposes Targeted Sanctions and Export Restrictions on Burma in Response to Military Coup

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published regulations in the Federal Register on January 15, 2021 to implement Executive Order 13936 (“E.O. 13936”), titled “The
Continue Reading OFAC Implements Hong Kong-Related Sanctions Regulations Pursuant to E.O. 13936