Key Notes:

  • 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

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

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

On July 29, 2024, both the Departments of Commerce and State issued separate but complementary proposed rules seeking public comment on enhanced restrictions on exports, reexports, or support to military or intelligence end users and end uses in countries of concern, consistent with the Fiscal Year 2023 National Defense Authorization Act (NDAA). The Department of Commerce’s

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued a Final Rule that redesignates regulations governing the procedures for the review of certain transactions involving information and communications technology and services (ICTS) designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a

On July 10, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published guidance summarizing the actions it takes to identify and inform industry about parties that present diversion risks to countries or entities of concern. This guidance is offered in an effort “to address the evolving tactics of our adversaries to circumvent

BIS Prohibition on Kaspersky Products

On June 20, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Determination that bans a range of transactions involving Kaspersky Lab, Inc. and its related entities’ (Kaspersky) cybersecurity and anti-virus products and services. The Final Determination prohibits Kaspersky from engaging in certain Information

On June 12, 2024, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) announced new sanctions and export control restrictions on Russia and Belarus. These measures have significant implications for companies that do business with or in these regions, as they may face new licensing requirements, limitations, or prohibitions

On May 17, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a Final Rule revising the Section 232 tariff exclusion process for imported steel and aluminum products. These changes, effective July 1, 2024, are intended “to refine the framework under which exclusions from the tariffs on steel and aluminum can be requested