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
BIS Issues FAQs on Foreign Military Sales
By Scott E. Diamond** on
On May 12, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a series of Frequently Asked Questions (FAQs) in an effort to respond to numerous questions from industry regarding the export of items that have been moved from the U.S. Munitions List under the International Traffic in Arms Regulations (ITAR) to…
Commerce Issues Fine for Misrepresentations Made in CJ Request
By Scott E. Diamond** on
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…
BIS Adds Seven Chinese Supercomputing Entities to Entity List for Their Support of China’s Military Modernization and Other Destabilizing Efforts
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…
Updated: United States Implements Multiple Sanctions and Export Restrictions on Russia
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…
United States Implements Multiple Sanctions and Export Restrictions on Russia
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…
BIS Implements Additional Export Restrictions on Burma
By Scott E. Diamond** on
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…
BIS Restricts Exports of Sensitive Items to Burma’s Military and Security Services
By Scott E. Diamond** on
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…
BIS Issues Interim Final Rule Expanding Certain Controls on Activities of U.S. Persons
By Scott E. Diamond** on
On January 15, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule implementing further provisions of the Export Control Reform Act of 2018 by: (i) imposing additional export license requirements under the Export Administration Regulations (EAR) in connection with certain military-intelligence end uses and end users; (ii) clarifying…
Commerce Adds and Removes Entities on Entity List and the MEU List
By Scott E. Diamond** on
On January 14, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice announcing the addition and removal of certain Chinese and Russian entities from the Entity List and the Military End-User (MEU) List.
Notably, BIS added China National Offshore Oil Corporation Ltd. to the Entity List for its…