As a reminder to our readers, the annual encryption self-classification report and semi-annual sales report for certain encryption items are due to be filed by February 1, 2023. 

Annual Self-Classification Report

The self-classification report covers less sensitive items covered under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e.

Effective December 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 36 Chinse entities to BIS’s Entity List. These additions are intended to further restrict China’s “ability to leverage artificial intelligence, advanced computing, and other powerful, commercially available technologies for military modernization and human rights abuses,” according

Effective December 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule announcing that it was moving nine Russian companies from the Unverified List to the more restrictive Entity List. BIS stated it has continuously been unable to verify the bona fides of these companies due to the Russian

On December 5, 2022, the Department of State’s Directorate of Defense Trade Controls (DDTC) released updated Compliance Program Guidelines that provide an overview of what it considers an effective compliance program. The document also provides both an introduction to the Arms Export Control Act (AECA), the International Traffic in Arms Regulations (ITAR), and the 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

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

On October 7, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule  implementing additional export controls on advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items. BIS made clear in its announcement that advanced computing items and “supercomputers” can be used

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.”

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

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