- The final rule took effect September 16. It codifies the series of “policy memoranda” BIS began issuing in 2022 to clarify the agency’s evolving attitude toward voluntary self-disclosures, which in turn aimed to encourage companies, universities and individuals to engage in the process after believing a violation of the Export Administration Regulations, or
OFAC Again Extends Authorizations Under Russia General License 13
On September 30, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13K, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import
State Department Largely Adopts Proposed Rule Extending License Exemptions for Australia and the United Kingdom into an Interim Final Rule
On August 20, 2024, the State Department published an Interim Final Rule in the Federal Register amending the International Traffic in Arms Regulations (ITAR) to add a license exemption regime for exports, reexports, transfers, and temporary imports of defense articles and defense services to and between Australia and the United Kingdom. The Interim Final Rule
OFAC Publishes Interim Final Rule Extending Recordkeeping Requirement to 10 Years
On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Interim Final Rule to amend its Reporting, Procedures and Penalties Regulations under 31 C.F.R. Part 501, which extends recordkeeping requirements for certain transactions from 5 years to 10 years. This Interim Final Rule takes effect on March 12
Department of Labor Updates List of Goods Produced by Forced Labor
On September 5, 2024, the Department of Labor (DOL) released a revised version of its List of Goods Produced by Child Labor or Forced Labor. This 2024 report identifies the types of goods, the industries involved and the countries that the DOL has reason to believe are produced by child labor or forced labor
OFAC Issues Revised Russia Telecommunications General Licenses and an Alert on Russian Attempts to Evade Sanctions
On September 4, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia General License (GL) 25E that continues to authorize all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. This continues to allow for services incident to the exchange of
USTR Announces Another Delay in Upcoming Changes to China Section 301 Tariffs
On August 30, 2024, the Office of the United States Trade Representative (USTR) issued a press release stating that the agency “intends” to publicize tariff increases on certain products subject to the China section 301 investigation “in the coming days.” The press release addresses the second self-imposed deadline missed by the USTR; initially, the agency
BIS Expected to Propose Barring Chinese Software in Autonomous and Connected Vehicles
On March 1, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Advanced Notice of Proposed Rulemaking (ANPRM) to explore national security risks posed by connected vehicles (CVs) that incorporate Information and Communications Technology and Services (ICTS) from “foreign adversaries,” including China and the Hong Kong Special Administrative Region. The initiative
Following U.S. Lead, Canada Announces New Tariffs on Chinese EVs, Steel and Aluminum
On August 26, 2024, the Department of Finance Canada announced the country would introduce a 100% tariff on Chinese-made electric vehicles (EVs) and a 25% tariff on certain Chinese steel and aluminum products. The press release, citing “unfair, non-market policies and practices” by China coupled with a “lack of rigorous labour and environmental standards,” thus
On the Eve of Ukrainian Independence Day, the United States Expands Export Controls and Sanctions on Russia and Belarus
On August 23, 2024—one day before Ukrainian Independence Day—the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of the Treasury, and the Department of State commemorated the milestone by expanding U.S. export controls and sanctions on Russia and Belarus. Notably, the agencies’ actions also come amidst Ukraine’s surprise incursion into Russia’s Kursk