The latest on Russia sanctions from the International Trade and Supply Chain Team
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On Monday, August 28, 2023, the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce issued a Proposed Rule that, if implemented, would make significant changes to

Continue Reading Biden Administration Proposes Significant Changes to Section 232 Exclusion Process

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

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the issuance of a $300 million penalty against Seagate Technology LLC and its Singapore affiliate, Seagate Singapore

Continue Reading BIS Levies Record Penalty for Export Control Violations related to Huawei Shipments

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

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

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

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