On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50, div. D. Part of the Act included a provision extending the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) from five years to 10 years. The new statute of limitations took effect on the date of the President’s signature.
Export Controls
The Government Continues to Prioritize Export Control and Sanctions Enforcement Highlighted in New Tri-Seal Compliance Note and Cooperative Agreement Between BIS and OFAC.
On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national security laws. The Compliance Note highlights the new changes made to the Department of Justice’s voluntary self-disclosure policy. The Note also provided an overview…
BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners
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 conjunction with the G7 meetings, BIS stated these new restrictions are designed to better align U.S. controls with those of its partner and ally countries…
BIS Levies Record Penalty for Export Control Violations related to Huawei Shipments
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 International Headquarters Pte. Ltd., (collectively, “Seagate”) to resolve apparent violations of the Huawei foreign direct product rule (the “Huawei FDP Rule”). BIS stated this case…
Biden Administration Increases Tariffs on Russian Aluminum and 100 Other Products on One-Year Anniversary of Russia’s Invasion of Ukraine
On February 24, 2023, the Biden Administration announced the imposition of additional tariffs on Russian imports of aluminum and approximately 100 other individual products. The imposition of these additional tariffs was announced on the one-year anniversary of Russia’s invasion of Ukraine. The White House announced its continued support of Ukraine in a series of actions…
BIS Issues New Export Controls and Entity List Additions Targeting Russia on One-Year Anniversary of Invasion
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 against Ukraine. The Biden Administration’s measures come on the one-year anniversary of Russia’s invasion of Ukraine and the first announcement by several Western countries, including…
Biden Administration No Longer Approving Export Licenses to Chinese Tech Giant Huawei
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 long sought to restrict Huawei’s access to advanced U.S. computer chips used to power 5G networks and related technological applications. Under the current export restrictions…
OFAC Continues to Take Aim at Russia’s Financial Sector with More SDN Designations
On December 15, 2022, the Office of Foreign Assets Control (“OFAC”) added 18 entities in Russia’s financial services sector to the Specially Designated Nationals and Blocked Persons List (“SDN List”). The US State Department concurrently designated Vladimir Potanin, one of the richest men in Russia.
OFAC designated Public Joint Stock Company Rosbank (“Rosbank”), a bank…
June 2022 Trade Law Update
In Husch Blackwell’s June 2022 Trade Law Update you’ll learn about the following updates in international trade and supply chain law:
- An update on U.S. Department of Commerce decisions
- U.S. International Trade Commission – Section 701/731 proceedings
- Customs and Border Protection case summaries
- Summary of decisions from the Court of International Trade
- June export controls
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OFAC and State Department Designate Severstal, Nord Gold and Additional Russians as SDNs
On June 2, 2022, the Office of Foreign Assets Control (OFAC) added new Russian vessels and aircraft used by Russian elites, new top Russian government officials, and their companies and operations to the Specially Designated Nationals (SDN) List for aiding in the continued war effort by Russia against Ukraine. Notably, these designations include more Russian government officials and oligarchs, and two of the largest mining companies in Russia, Severstal PJSC (Severstal) and Nord Gold PLC (Nord Gold). This means that U.S. persons cannot engage in any transactions with Severstal or Nord Gold unless authorized by a license.