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
BIS Adds 32 Entities and Persons to Unverified List
On March 24, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 32 persons and entities to its Unverified List (UVL). The UVL contains the names and addresses of foreign persons who are or have been parties to a transaction involving the export, reexport, or transfer (in-country) of
Commerce, Justice and the Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls
On March 2, 2023, the Departments of Commerce, Justice and the Treasury issued a joint Compliance Note cautioning financial institutions and multinational companies subject to U.S. jurisdiction to “be vigilant against efforts by individuals or entities to evade sanctions and export control laws.” The Compliance Note emphasizes the “unprecedented scope and scale” of sanctions against
BIS Adds 37 Entities to Entity List for National Security Risk Activities Involving Burma, China, Iran and Russia
- Three entities in Russia,
New Export Control Measures on Iran Address Iranian UAVs and Their Use by Russia in War with Ukraine
On February 24, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule amending the Export Administrations Regulations (EAR) to impose new export control measures on Iran. These measures address the use of Iranian Unmanned Aerial Vehicles (UAVs) (aka, Unmanned Aircraft System (UAS), aka drones) by Russia in its ongoing
BIS Adds Nearly 100 Russia-Related Entities to Entity List and Tightens Other Export Controls and Lists
On February 24, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued three Final Rules addressing Russia’s continued war against Ukraine. One rule expands existing industry sector sanctions and export controls already in place toward Russia and Belarus. The other two rules add Russian and third country entities to the Entity List
BIS Seeks Comments on Effectiveness of Licensing Procedures for Export of Agricultural Commodities to Cuba
On February 17, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a notice in the Federal Register seeking public comments on the effectiveness of the licensing procedures for the export and reexport of agricultural commodities to Cuba under the Export Administration Regulations (EAR). Specifically, the notice indicates that pursuant to section
BIS Announces Expedited Licensing Review for Exports to Turkey and Syria to Assist with Earthquake Relief Efforts
On February 17, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a statement indicating that it will expedite the processing of export license applications for items needed to assist in ongoing relief efforts in Turkey and Syria in response to the massive earthquake on February 6, 2023.
Turkey and Syria are
Annual and Semi-Annual Encryption Reports Due to BIS by February 1, 2023
As a reminder to our readers, the annual encryption self-classification report and semi-annual sales report for certain encryption items are due to be filed by February 1, 2023.
Annual Self-Classification Report
The self-classification report covers less sensitive items covered under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e.
BIS Adds 36 Chinese Companies to Entity List for Support of China’s Military Modernization, Human Rights Violations and UAV Concerns
Effective December 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 36 Chinse entities to BIS’s Entity List. These additions are intended to further restrict China’s “ability to leverage artificial intelligence, advanced computing, and other powerful, commercially available technologies for military modernization and human rights abuses,” according