Export Control

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On June 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it would be delaying the effective date for certain filing requirements set forth in April 2020 regulations on military-related exports to China, Russia and Venezuela. After significant pushback from industry representatives that more time was needed to transition to…

In collaboration with our foreign law firm partners, we continue to update our chart of COVID-19 measures taken by governments around the world. The government measures in the chart include economic, labor and employment, health and safety, and export and import measures. Below is a list of the updated countries and a summary of the…

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced on June 15, 2020 that it is issuing a new rule to allow persons to share certain U.S. technology with Huawei Technologies Co., Ltd. (“Huawei”) in connection with standards development in a standards setting body, despite Huawei’s designation to the Entity List.   Commerce…

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued an Interim Final Rule amending General Prohibition Three, also known as the foreign-produced direct product reexport rule, so that this General Prohibition applies to certain additional foreign-made items destined for certain persons designated with a new footnote on BIS’ Entity List. Specifically, this…

Due to continuing concerns with Huawei Technologies and its non-U.S. affiliates accessing and using U.S. technology and software to design and manufacture its semiconductors, the Department of Commerce (Commerce) announced that it will further tighten export restrictions on the Chinese conglomerate. Commerce’s  Bureau of Industry and Security (BIS) will amend its foreign-produced direct product rule…

On May 14, 2020, the U.S. Departments of State and Treasury and the U.S. Coast Guard issued a global advisory to alert the maritime industry and those active in the energy and metals sectors to deceptive shipping practices used to evade U.S. economic sanctions.  It is intended to provide exporters, shippers and others utilizing the…

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued two final rules and one proposed rule intended to prevent efforts by entities in China, Russia and Venezuela to acquire U.S. technology that could be used in development of weapons, military aircraft or surveillance technology through civilian supply chains or under civilian-use pretenses.…

On April 23, 2020, the Department of State’s Directorate of Defense Trade Controls (DDTC) announced certain measures to mitigate the impact of the pandemic on U.S. companies and supply chains overseas. Key measures from the announcement are summarized below.

Compliance/Registration

  • Effective for registrations originally expiring between February 29 and June 30, 2020, registrations as a

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On April 7, 2020, the U.S. Department of Homeland Security’s Federal Emergency Management Agency (FEMA) issued a temporary final rule (“Rule”) to establish export restrictions on certain types of personal protective equipment (PPE) products and respirators (“Covered Products”) used in the response to the COVID-19 pandemic. The Rule implements the presidential memorandum dated April 3,…

On April 17, 2020, the Federal Emergency Management Agency’s (FEMA) filed a notification of exemptions (the “Exemptions”) that identifies 10 exemptions from the temporary final rule published on April 10, 2020 (the “Rule”), which restricts the export from the United States of certain personal protective equipment (PPE) and respirators in the response to the COVID-19…