In addition to its role in enforcing U.S. export control laws, the Department of Commerce’s Bureau of Industry and Security (BIS) is charged with administering and enforcing the antiboycott laws under the Export Administration Act. These antiboycott laws were adopted to encourage and, in some circumstances, require U.S. companies to refuse to participate in foreign
BIS Issues Policy Memo on the Voluntary Self-Disclosure Process
- The policy memorandum builds upon two previous updates to the VSD process announced in June 2022 and April 2023. It gives direction to companies wishing to take advantage of certain faster processing options for VSDs.
- Cuts some requirements for submissions of minor or technical infractions of U.S. export controls to reduce the administrative
BIS Implements Additional Sanctions Against Russia and Belarus
Effective January 25, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) again expanded export controls and sanctions against Russia for its continuing aggression against Ukraine and Belarus for its complicity in such activities. In a Final Rule, BIS is expanding the scope of the Export Administration Regulations’ (EAR) Russian and Belarusian…
Annual and Semi-Annual Encryption Reports Due to BIS by February 1, 2024
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, 2024.
Annual Self-Classification Report
The self-classification report covers less sensitive items described under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e., …
BIS Adds 13 Chinese Entities to Unverified List
On December 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 13 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 items subject…
OFAC and BIS Further Sanction Belarusian and Russian Entities and Individuals
On December 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) imposed sanctions on numerous entities and individuals in order to place additional pressure on both Belarus and Russia. The OFAC sanctions focus on Belarus’ “authoritarian regime” and for its…
OFAC, State and BIS Announce Further Sanctions on Companies Supporting Russia’s War Efforts
On November 2, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State, and the Department of Commerce’s Bureau of Industry and Security (BIS) announced a combined effort to designate and sanction numerous additional Russian individuals and entities who have been determined to be assisting in the war against…
Commerce Issues Further Export Controls Targeting China’s Semiconductor Manufacturing and Advanced Computing Capabilities
- These two Interim Final Rules reinforce the October 7, 2022, controls appended to the EAR to restrict China’s ability to both purchase and manufacture certain high-end chips critical for military advantage.
- The rules impose controls on additional types of semiconductor manufacturing equipment, adjust the parameters that determine whether an advanced computing chip is
BIS Halts New Licenses for Firearm Exports
On October 27, 2023, the U.S. Department of Commerce announced an immediate pause on the issuance of new export licenses for certain firearms, related components and ammunition for a period of approximately 90 days. This pause applies globally to all non-governmental end users with some exceptions, notably for Ukraine, Israel and countries in Country Group…
U.S. Supreme Court Declines to Hear Section 232 Steel Appeal
On October 30, 2023, the U.S. Supreme Court declined to hear another Section 232 national security steel tariff appeal. On July 21, 2023, PrimeSource Building Products, Inc. filed Petition for a Writ of Certiorari with the U.S. Supreme Court, after the U.S. Court of Appeals for the Federal Circuit reversed the lower court decision of…

