On October 31, 2024, the Department of Homeland Security (DHS) announced that effective November 1, 2024, four textile Chinese entities have been added to the UFLPA Entity List. These entities have been determined by DHS to be facilities and entities that source material from the Xinjiang Uyghur Autonomous Region or from persons working with the
BIS, DDTC Publish a Series of Rules to Modernize U.S. Space-Related Export Controls
On October 17, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) released three rules—one Final Rule, one Interim Final Rule, and one Proposed Rule—to reduce controls on a variety of less sensitive space-related items, thereby ensuring the U.S. space industrial base remains globally competitive while also bolstering the U.S. international space partnerships. Concurrently
BIS Adds 26 Companies to the Entity List
On October 21, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 26 companies to its Entity List for activities contrary to U.S. national security and foreign policy for alleged violations of export controls, involvement in weapons programs of concern, and evasion of U.S. sanctions and export controls
USTR Opens Section 301 Tariff Exclusion Process for Certain Machinery from China Used in Domestic Manufacturing
On October 15, 2024, the Office of the United States Trade Representative (USTR) announced that it has opened a process for interested parties to request that certain machinery from China be temporarily excluded from Section 301 duties in the “Investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation”. Upon
OFAC Expands Sanctions on Iran for Missile Attack on Israel
On October 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was expanding sanctions on Iran’s petroleum and petrochemical sectors in response to Iran’s October 1 attack on Israel. The Secretary of the Treasury has identified the petroleum and petrochemical sectors of the Iranian economy pursuant to a
BIS Enhances Its Enforcement Discretion: Final Rule Revamps Voluntary Self-Disclosure Process, Abolishes Penalty Caps and Amends Penalty Guidelines
- 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