UPDATE: On November 1, 2022, U.S. Customs and Border Protection (CBP) issued a message announcing that implementation of its Uyghur Forced Labor Prevention Act (UFLPA) Region Alert is postponed until further notice. CBP stated that its Office of Trade “is actively working with impacted users to address concerns” and that a new implementation date will
New Export Controls Target Support for China’s Advanced Computing and Semiconductor Manufacturing
Key Notes:
- The Rule restricts exports to China of high-end chips and semiconductor manufacturing equipment, including foreign made items that are the product of U.S. technology.
- The Rule restricts the export of a wide range of items that would support certain supercomputing or integrated circuit production end-uses in China. In some circumstances, any item subject
Treasury Department Releases CFIUS Enforcement and Penalty Guidelines
Key Notes:
- The Treasury Department recently released guidelines specifying conduct that may be considered a violation of CFIUS regulations.
- The guidelines provide information about how CFIUS gathers information and the formal penalty process.
- They also indicate factors that CFIUS may consider in making an enforcement determination, including aggravating and mitigating factors.
On September 15, 2022,
Commerce, Treasury and State Departments Issue Joint Alert on Russia Sanctions and Export Controls
On October 14, 2022, the Departments of Commerce, Treasury and State issued a joint alert regarding the Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex. The alert provides a summary of the major actions taken by Treasury’s Office of Foreign Assets Control (OFAC) and Commerce’s Bureau of Industry and Security (BIS) with
BIS Adds 31 Chinese Entities to its Unverified List, Issues Guidance on End-Use Checks
On October 7, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 31 Chinese entities to its Unverified List on the basis that it has been “unable to verify their bona fides because an end-use check could not be completed satisfactorily for reasons outside the U.S. Government’s control.”
OFAC Expands Russia Sanctions Following Putin’s Illegal Annexation of Four Ukrainian Regions
On September 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated hundreds of Russian individuals and entities and placed them on the Specially Designated Nationals (SDN) List in response to Russia’s illegal annexation of additional Ukrainian territories.
The new designations target 14 suppliers connected to the country’s military-industrial complex, including
Commerce Adds Numerous Russian Entities to BIS’ Entity List
On September 30, 2022, in response to Russia President Vladimir Putin’s illegal effort to annex further Ukrainian territory, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that added 57 entities located in Russia and the Crimea region of Ukraine to the Entity List for supporting the Russian military’s continuing
OFAC Sanctions Facilitators of Iranian Oil Sales
On September 29, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of international companies for facilitating the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to South and East Asia. OFAC targeted the network, which includes a myriad of front companies in
OFAC Issues Updated Iran General License Covering Certain Services, Software and Hardware for Communications
On September 23, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Iran General License (GL) D-2 which authorizes the export, reexport by U.S. persons to Iran of certain services, software and hardware incident to communication. The purpose of the revised GL is to bring this OFAC guidance on
Annual Blocked Property Reports Due to OFAC by September 30
All U.S. persons and persons otherwise subject to U.S. jurisdiction, not only U.S. financial institutions, holding property blocked pursuant to various OFAC sanctions programs must file their annual reports on such blocked property by September 30, 2022. This report is pursuant to 31 C.F.R. §§ 501.603. This report must include all blocked property held as