On December 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) imposed sanctions on numerous entities and individuals in order to place additional pressure on both Belarus and Russia. The OFAC sanctions focus on Belarus’ “authoritarian regime” and for its
EAR
OFAC, State and BIS Announce Further Sanctions on Companies Supporting Russia’s War Efforts
On November 2, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State, and the Department of Commerce’s Bureau of Industry and Security (BIS) announced a combined effort to designate and sanction numerous additional Russian individuals and entities who have been determined to be assisting in the war against…
Commerce Issues Further Export Controls Targeting China’s Semiconductor Manufacturing and Advanced Computing Capabilities
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BIS Continues to Focus on and Sanction Entities Providing Support to Russia’s Military and Defense Industries
On October 6, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) added 49 entities from China, Estonia, Finland, Germany, India, Turkey, United Arab Emirates (UAE), and the United Kingdom to the Entity List after determining that these companies were “acting contrary to the national security or foreign policy interests of the United…
U.S., UK and EU Announce Updated List of Controlled “High-Priority” Items Restricted for Export to Russia
On September 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced additional items considered significant to Russian weaponry and are now restricted for export to both Russia and Belarus. In coordination with the United Kingdom and European Union, BIS continues to identify “high-priority items” by their six-digit Harmonized System (HS)…
Commerce Issues Policy Memo to Incentivize More Disclosures of Export Violations
To increase disclosures of export violations, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a memorandum on April 18, 2023 “clarifying” its enforcement policy related to voluntary self-disclosures of “significant” possible violations of the Export Administration Regulations (EAR). The memo also elaborates upon the policy regarding disclosures of potential EAR violations by…
BIS Imposes $300 Million Civil Penalty Related to Exports to Huawei and Violation of FDP Rule

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…
BIS Adds 28 Entities to the Entity List for Supporting Russia’s Military/Defense Industrial Base
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…
BIS Releases Human Rights FAQs for Export License Applications
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…
BIS Amends EAR to Explicitly Include Protection of Human Rights, Adds 11 Entities to Entity List
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…