Export Control

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On March 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended General License 1A “Official Business of the United States Government” and General License 2A “Authorizing the Wind Down of Transactions Involving the Nicaraguan National Police” to clarify they were also issued under the Nicaraguan Human Rights and…

In its continuing effort to tighten economic sanctions on Iran, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned five United Arab Emirates (UAE)-based companies that facilitate the Iranian regime’s petroleum and petrochemical sales. According to OFAC, these companies in 2019 “collectively purchased hundreds of thousands of metric tons of petroleum…

UPDATED: April 6, 2020 – Major operational changes continue at trade-related U.S. government agencies and courts  due to personnel and public safety concerns over the COVID-19 outbreak in the United States. Below is currently available information on their status. Overall, the Office of Personnel Management has announced that as of March 16, 2020, and until…

On February 24, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice announcing amendments to the Export Administration Regulations (EAR) that revise export licensing policy toward the Russian Federation and Yemen based on national security and foreign policy concerns. Under the EAR, BIS has established various “Country Group”…

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued a Federal Register notice renewing the temporary general license for Huawei Technologies Co., Ltd. and 114 of its non-U.S. affiliates on the Entity List until April 1, 2020. As published on May 22, 2019, this temporary general license authorizes certain activities, including those…

On December 13, 2019, the U.S. Department of Justice (DOJ) released a revised policy for companies regarding voluntary self-disclosures of export control and sanctions violations. The revised policy was effective on the date of its release and will be formally incorporated into the Justice Manual. In releasing the revised Voluntary Self-Disclosure Policy (VSD Policy),…

On December 30, 2019, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued an interim final rule seeking to amend the International Traffic in Arms Regulations (ITAR) with definitions more clearly explaining activities that are not considered to be exports, reexports, retransfers or temporary imports of secured and unclassified technical data. This …

The Department of Commerce’s Bureau of Industry and Security (BIS) announced this week that it will again extend the temporary general license it issued in May 2019 (see Trump and Trade Update of May 21, 2019 and August 19, 2019) that partially continued the availability of exports under the Export Administration Regulations (EAR) for …

In May 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published the Framework for OFAC Compliance Commitments (“Framework”), which is intended to help organizations subject to U.S. jurisdiction, as well as foreign entities doing business in or with the United States, U.S. persons, or using U.S.-origin goods or services, to develop…