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

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule effective October 29, 2020 amending Section 742.4(b)(7) of the Export Administration Regulations (“EAR”) to revise
Continue Reading BIS Amends License Review Policy for National Security Controlled Items Destined for China, Venezuela, and Russia

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently published an Advanced Notice of Proposed Rulemaking (“ANPRM”) regarding the identification and review of controls for certain “foundational
Continue Reading BIS Seeks Comments on Identifying “Foundational Technologies”

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has announced that it is further restricting access by Huawei Technologies Co. Ltd. and its designated non-U.S. affiliates (“Huawei”) to U.S.-produced technology and software.  As we have previously discussed, BIS first added Huawei to its Entity List on May 15, 2019 and has continued to impose additional export restrictions on Huawei under the U.S. Export Administration Regulations (“EAR”).  Most recently, BIS published a Federal Register notice to implement the following enhancements.  Although BIS published this Federal Register notice on August 20, 2020, the following rule changes took effect retroactively as of August 17, 2020:
Continue Reading U.S. Adds 38 New Huawei Affiliates to Entity List While Again Expanding Foreign-Produced Direct Product Rule