Supplemental Joint Alert: BIS & FINCEN Urge Companies To Continue Their Vigilance Against Attempts To Evade Export Controls And Sanctions On Russia & Belarus
On May 19, 2023, the Commerce Department’s Bureau of Industry and Security (“BIS”) and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Supplemental Joint Alert urging financial institutions (e.g., banks, credit card operators, and foreign exchange dealers) to continue their vigilance against attempts by individuals and entities to evade U.S. export controls on […]
BIS Implements Additional Sanctions Against Russia, Belarus, Crimea and Iran
On May 23, 2023, BIS published a Final Rule amending the Export Administration Regulations (“EAR”) to expand the current export controls and sanctions levied against Russia and Belarus, Crimea, and Iran in response to the ongoing aggression against Ukraine. The new controls took effect on May 19, 2023, and are intended to enhance and strengthen […]
BIS Publishes Clarifying Memorandum On The Concrete Benefits And Costs Of VSDs And Blowing The Whistle On Others
On April 18, 2023, the Commerce Department’s Bureau of Industry and Security (“BIS”) released a memorandum entitled “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning Others” (“the Memorandum”), which represents a dramatic shift in BIS’ current export enforcement policy. Going forward, as discussed in greater detail below, a company’s decision not to file a […]
BIS Proposes New Export Controls On Certain Automated Peptide Synthesizers
On April 20, 2023, the Commerce Department’s Bureau of Industry and Security (“BIS”) published a Proposed Rule for the imposition of export controls on certain automated peptide synthesizers typically used in biotechnology research and development activities. BIS proposes to treat such equipment as emerging and foundational technologies that are essential to U.S. national security under […]
The Disruptive Technology Strike Force
The U.S. Justice and Commerce Departments Announce Their New Export and Sanctions Enforcement Initiative: The Disruptive Technology Strike Force On February 16, 2023, the Department of Justice (“DOJ”) and the Commerce Department (“DOC”) issued a joint press release announcing the launch of the new Disruptive Technology Strike Force (“DIS-TECH Strike Force”). It will be led […]
BIS Rolls Out New Export Controls on Cybersecurity Items Used in Surveillance of Private Citizens and Other Malicious Cyber Activities
On October 21, 2021, the Bureau of Industry and Security (BIS) published an Interim Final Rule with a Request for Public Comments establishing new export controls on cybersecurity items under the Export Administration Regulations (EAR), as well as new License Exception Authorized Cybersecurity Exports (ACE). BIS is also seeking comments about the impact of the […]
USTR Issues Notice and Request for Comments on Reinstatement of Expired Section 301 Product Exclusions
On October 5, 2021, the Office of the U.S. Trade Representative (USTR) published a Notice and Request for Comments on the possible reinstatement of expired product exclusions from the Section 301 tariffs on China. Comments must be submitted to the public docket on the web portal at https://comments.USTR.gov on or before December 1, 2021. The […]
FMC Announces 8 Recommendations to Improve Supply Chain Congestion
FMC Commissioner Rebecca Dye presented eight (8) interim recommendations to address supply chain congestion across the United States, and she plans to hold meetings in the near future with Supply Chain Innovation Teams to address container disruptions and increase supply chain visibility.
Federal Maritime Commission’s Ocean Carrier Audit Program
The “Vessel Operating Common Carrier Audit Program” has a dedicated audit team that will assess carrier compliance with the FMC’s rule on detention and demurrage and provide information it considers beneficial to monitoring the marketplace for ocean cargo services.
U.S. Government Agencies Warn Companies of Risks of Doing Business in Hong Kong
The Departments of Commerce, Homeland Security, State and Treasury issued a Business Advisory on July 16, 2021 warning of the risks of doing business in Hong Kong.