On April 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) imposed a $300 million civil penalty against Seagate Technology LLC (California) and Seagate Singapore International Headquarters Pte. Ltd. (Singapore) to resolve alleged violations of U.S. export controls related to selling hard disk drives (HDDs) to Huawei Technologies Co. Ltd. (Huawei) in

On April 12, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule in which it added 28 entities to the Entity List. The entities are companies located in Armenia , China, Malta, Russia, Singapore, Spain, Syria, Turkey, the United Arab Emirates (UAE), and Uzbekistan. Each was placed on the

On March 30, 2023, the Department of Commerce’s Bureau of Industry and Security released a series of Frequently Asked Questions (FAQs) regarding human rights concerns and export controls. The FAQs address BIS’ authority under the Export Administration Regulations (EAR) to consider human rights concerns when reviewing export license applications, and states that exporters “are expected

On March 28, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to confirm that the foreign policy interest of protecting human rights worldwide is a basis for adding entities to the Entity List. Specifically, this Final Rule amends 15 C.F.R. § 744.11 of the EAR regarding

On March 27, 2023, the U.S. Supreme Court denied a petition by USP Holdings, Inc. and related parties challenging the Trump administration’s Section 232 tariffs on steel imports. The steel importer petitioners had asked the Court to reverse aspects of a June 2022 decision by the U.S. Court of Appeals for the Federal Circuit (and

On March 23, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Notice of Proposed Rulemaking implementing measures to prevent the improper use of CHIPS Act Incentives Program funding. Described as “guardrails,” the proposed rules are intended to ensure technology and innovation funded by the Creating Helpful Incentives to Produce Semiconductors

On March 24, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 32 persons and entities to its Unverified List (UVL). The UVL contains the names and addresses of foreign persons who are or have been parties to a transaction involving the export, reexport, or transfer (in-country) of

On March 15, 2023, U.S. Customs and Border Protection (CBP) announced that it has activated two new license codes for use in the Automated Export System (AES). These new codes are related to an Interim Final Rule published by the Department of Commerce’s Bureau of Industry and Security (BIS) on October 13, 2022, that

On March 2, 2023, the Departments of Commerce, Justice and the Treasury issued a joint Compliance Note cautioning financial institutions and multinational companies subject to U.S. jurisdiction to “be vigilant against efforts by individuals or entities to evade sanctions and export control laws.” The Compliance Note emphasizes the “unprecedented scope and scale” of sanctions against

On March 2, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 37 entities to the Entity List for contributing to Russia’s military/defense industrial base, supporting China’s military modernization, and facilitating or engaging in human rights abuses in Burma and China, including the following:

  • Three entities in Russia,