The latest on Russia sanctions from the International Trade and Supply Chain Team
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On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan.  In

Continue Reading BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners

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 Obligations

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 Huawei

We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at how

Continue Reading International Trade Law: 2022 Year in Review & Outlook for 2023

On September 16, 2022, the Biden Administration announced the final rule regarding a two-year pause on the imposition of new anticircumvention duties on imports of solar cells and modules from


Effective January 13, 2022, the U.S. Census Bureau’s (“Census”) Automated Export System (“AES”) began issuing a response code 66Q notifying Electronic Export Information (“EEI”) filers whenever they enter an export
Continue Reading AES Now Requires Consistency with EAR Destination-Based Controls; Census Will Not Remove Domestic EEI Requirement for Puerto Rico & U.S. Virgin Islands Shipments

As previously reported  in our International Trade Insights blog, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added Chinese telecommunications giant Huawei Technologies Co. Ltd. (“Huawei”) and sixty-eight of its affiliate companies to the BIS Entity List effective May 16, 2019. This designation prohibits anyone inside or outside of the United States from exporting, re-exporting or making an in-country transfer of commodities, software or technology that is subject to the U.S. Export Administration Regulations (“EAR”) to any of the listed Huawei companies without an appropriate license from BIS.  Commodities, software and technology are “subject to the EAR” when they are of U.S. origin (regardless of whether they are located inside or outside the U.S.), physically present in the U.S., moving in transit through the U.S. or produced outside of the U.S. with qualifying amounts of controlled U.S.-origin content.  The BIS designations for these Huawei companies require BIS to evaluate any license applications according to a general presumption of denial.  BIS has also issued a Temporary General License (covered here in the International Trade Insights blog) which authorizes limited transactions with Huawei Entity List companies under certain contracts that existed on or before May 16, 2019.  This Temporary General License is currently scheduled to expire on August 19, 2019.
Continue Reading Trump Administration and BIS Announce Willingness to Issue Huawei Export Licenses; Criteria for Issuing Such Licenses Still Unclear