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…
USTR Opens Section 301 Tariff Exclusion Process for Certain Machinery from China Used in Domestic Manufacturing
On October 15, 2024, the Office of the United States Trade Representative (USTR) announced that it has opened a process for interested parties to request that certain machinery from China be temporarily excluded from Section 301 duties in the “Investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation”. Upon…
OFAC Expands Sanctions on Iran for Missile Attack on Israel
On October 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was expanding sanctions on Iran’s petroleum and petrochemical sectors in response to Iran’s October 1 attack on Israel. The Secretary of the Treasury has identified the petroleum and petrochemical sectors of the Iranian economy pursuant to a…
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 Again Extends Authorizations Under Russia General License 13
On September 30, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13K, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…
Department of Commerce Proposes Ban on Connected Vehicles Using Chinese or Russian Hardware and Software
- Proposed rule would prohibit the import and sale of connected vehicles equipped with certain hardware or software developed, manufactured, or supplied by Chinese or Russian-affiliated entities.
- Proposed rule would also prohibit the sale of connected vehicles manufactured by Chinese or Russian OEMs.
- Prohibitions would take effect between 2027 and 2030.
- If implemented, manufacturers
USTR Seeks Public Comments on Increase of China Section 301 Tariffs on Five HTSUS Subheadings
On September 20, 2024, the Office of the U.S. Trade Representative (USTR) announced that it is seeking public comments on proposed modifications announced on September 13, 2024 to the tariff actions in the Section 301 investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation. See Thompson Hine Update of…
OFAC Issues New & Updated Russia-Related General Licenses in Connection with Recent Designations
On September 13, 2024, the United States designated and placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List three entities and two individuals for their connection to Russia’s destabilizing actions abroad, particularly efforts to undermine and manipulate the outcome of the October 2024 Moldovan presidential election.
OFAC Issues Final Rule on Procedures Related to Blocking Property
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule on Updating Provisions Related to Blocking and Other Actions Related to Specific Property or Interests in Property. The rule is effective as of September 17, 2024.
The new rule aims to clarify OFAC’s process for issuing orders that block…
