On June 12, 2024, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) announced new sanctions and export control restrictions on Russia and Belarus. These measures have significant implications for companies that do business with or in these regions, as they may face new licensing requirements, limitations, or prohibitions
BIS Updates Section 232 Steel and Aluminum Tariff Exclusion Process by Removing 12 GAEs
On May 17, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a Final Rule revising the Section 232 tariff exclusion process for imported steel and aluminum products. These changes, effective July 1, 2024, are intended “to refine the framework under which exclusions from the tariffs on steel and aluminum can be requested…
BIS Revises Export Controls on Firearms Licensing Requirements
On April 30, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (IFR) updating the Export Administration Regulations (EAR) to enhance the control structure for firearms and related items under BIS’s jurisdiction. This IFR will be effective on May 30, 2024, and public comment will be accepted until…
BIS Establishes New License Exception for Medical Devices Exported to Russia, Belarus and Occupied Areas of Ukraine
On April 26, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule introducing the new License Exception MED that enables delivery of humanitarian medical devices to the citizens of Russia, Belarus, and the Crimea region of Ukraine, and the occupied regions of Donetsk and Luhansk. This license exception is an effort…
BIS and OFAC Expand Export Controls and Sanctions on Iran for Aggression Toward Israel and Military Support for Russia
On April 18, 2024, the Departments of Commerce and the Treasury announced combined export control restrictions and economic sanctions against Iran for its attack on Israel on April 13, 2024. These actions are intended “to degrade and disrupt key aspects of Iran’s malign activity, including its UAV [Unmanned Aerial Vehicles] program and the revenue the…
BIS Issues Interim Final Rule to Ease Export Controls on Australia and the United Kingdom
To “further enhance defense industrial base cooperation and technology innovation with Australia and the United Kingdom,” the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) on April 18, 2024 to ease various licensing requirements prescribed by the Export Administration Regulations (“EAR”) for exports, reexports, or transfers (in-country) to…
BIS Releases Interim Final Rule Further Revising Export Controls on Advanced Computing and Semiconductor Manufacturing
On April 4, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released another Interim Final Rule (IFR) offering clarification and correcting inadvertent errors made in earlier rulemakings regarding the implementation of significant export controls on certain advanced computing items and supercomputer and semiconductor end use. This latest rule is effective April 4…
Commerce Releases New Resource to Help Identify Boycott-Related Requests
On March 28, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a new resource to help identify boycott-related requests U.S. persons and companies may receive during the regular course of conducting business. The resource is a public list of entities identified as making a boycott-related request in reports received by the BIS…
BIS Amends EAR to Expand Export Controls on OFAC SDN-Listed Persons
On March 20, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule implementing restrictions under the Export Administration Regulations (EAR) on persons who have been designated and placed on the Specially Designated Nationals (SDN) List maintained by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). Under Secretary…
U.S. Imposes New Sanctions on Russia to Commemorate Second Anniversary of Russia’s Invasion of Ukraine
On February 23, 2024, the eve before Russia’s full-scale invasion of Ukraine officially enters its third year, the United States issued another sanctions package against Russia, taking particular aim at Russia’s financial sector, energy production revenue streams, and military-industrial complex. Specifically, the package sanctions more than 500 entities and individuals by having them added…

