Export Control

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The State Department’s Directorate of Defense Trade Controls (DDTC) on June 1, 2021 announced that a final rule from January 2020, which moved 3D-printed guns out from control under the International Traffic in Arms Regulations (ITAR) over to the Export Administration Regulations (EAR), is now in effect. See Federal Register notice of January 23, 2020…

On April 30, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a notice announcing a settlement and fine of over $300,000 to FLIR Systems, Inc. for an egregious violation of the Export Administration Regulations (EAR). This settlement highlights that violations of the EAR are not limited to physical exports of goods…

On April 12, 2021, the State Department’s Directorate of Defense Trade Controls (DDTC) issued additional guidance regarding changes that have been made to the International Traffic in Arms Regulations (ITAR) pertaining to export of defense articles or services to Russia. The guidance summarizes changes that were implemented on March 18, 2021, when the Departments of…

The U.S. Department of Commerce’s Bureau of Industry & Security (BIS) issued a final rule amending the Export Administration Regulations to eliminate most reporting requirements related to open source encryption software and certain “mass market” encryption items and to revise the Commerce Control List.

Key Notes:

  • BIS issued a final rule eliminating certain reporting requirements

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On April 8, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule adding seven Chinese supercomputing entities to the Entity List for “conducting activities that are contrary to the national security or foreign policy interests of the United States” due to their support of China’s military modernization and “other…

Note: This previously published client update has been revised to provide links to the official notices published by the Departments of Commerce and State on March 18, 2021.

On March 2, 2021, the Departments of Commerce, State and the Treasury imposed sanctions and export restrictions on numerous Russian officials and government entities in response to…

On March 2, 2021, the Departments of Commerce, State and the Treasury imposed sanctions and export restrictions on numerous Russian officials and government entities in response to the Russian Federation’s imprisonment and alleged previous poisoning of opposition figure Aleksey Navalny. These actions follow similar sanctions imposed by the European Union and the United Kingdom. Dozens…

On March 4, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) announced further export restrictions on Burma initially implemented in February 2021. See Update of February 18, 2021. These actions are in response to the coup in Burma on February 1, 2021, in which the military overthrew the democratically elected civilian…

On February 12, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that was implementing restrictions on the export of “sensitive items” to Burma’s Ministry of Defense, the Ministry of Home Affairs, armed forces, and security services in response to the Burmese military’s February 1 coup to overthrow the civilian government of…