The latest on Russia sanctions from the International Trade and Supply Chain Team
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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 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

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

This blog post covers several new sanctions and export controls that the U.S. government imposed on Russia and Belarus in the time period occurring between March 31, 2022 and April…
Continue Reading Summary of Changes in Russia/Belarus Export Controls and Sanctions Occurring From March 31, 2022 to April 22, 2022

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently issued a final rule amending the U.S. Export Administration Regulations (EAR) to add twenty-seven (27) companies and individuals to the BIS Entity List effective November 26, 2021. These companies and researchers are alleged to have ties to China’s military quantum computing efforts as well as Pakistani nuclear and missile proliferation. The new companies added include:…
Continue Reading BIS Blacklists Certain Entities with Ties to China, Pakistan and Russia

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 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 January 14, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it has amended the Export Administration Regulations (“EAR”) to formally implement the rescission…
Continue Reading BIS Amends EAR to Implement Rescission of Sudan’s State Sponsor of Terrorism Designation