On January 16, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule prohibiting the sale and importation of connected vehicles incorporating certain hardware and software components (or those components sold separately) with a sufficient nexus to the People’s Republic of China (PRC) or Russia. The new prohibitions go into
BIS Seeks to Further Strengthen Export Controls Targeting China’s Advanced Semiconductor Industry
On December 2, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued two new rulemakings in an ongoing effort to “further impair [China’s] capability to produce advanced-node semiconductors that can be used in the next generation of advanced weapon systems and in artificial intelligence (AI) and advanced computing, which have significant military…
BIS Announces New Controls on Exports to Pakistan
On November 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced new export controls targeting Pakistan to address concerns about the diversion of certain items to unauthorized end uses or end users, particularly those on the Entity List. The final rule, effective November 25, 2024, imposes new licensing requirements…
BIS, DDTC Publish a Series of Rules to Modernize U.S. Space-Related Export Controls
On October 17, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) released three rules—one Final Rule, one Interim Final Rule, and one Proposed Rule—to reduce controls on a variety of less sensitive space-related items, thereby ensuring the U.S. space industrial base remains globally competitive while also bolstering the U.S. international space partnerships. Concurrently…
BIS Adds 26 Companies to the Entity List
On October 21, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 26 companies to its Entity List for activities contrary to U.S. national security and foreign policy for alleged violations of export controls, involvement in weapons programs of concern, and evasion of U.S. sanctions and export controls…
BIS Enhances Its Enforcement Discretion: Final Rule Revamps Voluntary Self-Disclosure Process, Abolishes Penalty Caps and Amends Penalty Guidelines
- 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
OFAC Issues Revised Russia Telecommunications General Licenses and an Alert on Russian Attempts to Evade Sanctions
On September 4, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia General License (GL) 25E that continues to authorize all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. This continues to allow for services incident to the exchange of…
On the Eve of Ukrainian Independence Day, the United States Expands Export Controls and Sanctions on Russia and Belarus
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…
Commerce and State Departments Issue Proposed Rules Addressing Restrictions on U.S. Persons’ Support for Foreign Military, Intelligence, and Security Services and Controls to Protect National Security and Human Rights
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…
Commerce and Treasury Departments Announce New Sanctions and Export Control Restrictions on Russia and Belarus
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…
