Export Control

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On December 16, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced it was placing another eight Chinese technology firms on its Non-SDN Chinese Military-Industrial Complex Companies List (CMIC List). This action was taken pursuant to Executive Order 13959 (as amended by Executive Order 14032), which prohibits U.S. persons from conducting…

On December 9, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was amending the Export Administration Regulations (EAR) to apply more restrictive treatment to exports and reexports to, and transfers within, Cambodia of items subject to the EAR.  BIS stated that it is taking this action “to address recent…

On December 10, 2021, the United States joined Australia, Denmark and Norway in announcing the Export Controls and Human Rights Initiative in recognition that “advanced technologies are a vital part of global economic growth and communication, helping people become more interconnected, share knowledge, and advance freedom, democracy, and opportunity” while also acknowledging that authoritarian governments…

On November 26, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule in the Federal Register adding 27 foreign entities and individuals to the Entity List for engaging in activities that are contrary to the national security or foreign policy interests of the United States. These entities and individuals…

On November 30, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Notice of Inquiry in the Federal Register seeking public comments regarding areas and priorities for United States and European Union (EU) export control cooperation. This information gathering is intended to inform and assist the work of the U.S.-EU Trade…

Effective November 1, 2021, the Department of State’s Directorate of Defense Trade Controls (DDTC) amended the International Traffic in Arms Regulations (ITAR) to add and update entries for Ethiopia and Eritrea, respectively. As a result, it is now the policy of the United States to deny licenses and other approvals for exports of defense articles…

On October 21, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS), released an Interim Final Rule to implement export controls on certain cybersecurity items that can be used for malicious cyber activities. Public comments are accepted until December 6, 2021. The final rule will become effective on January 19, 2022, and will…

The Commerce Department’s Bureau of Industry and Security (BIS) has released a final rule to implement a multilateral agreement to control certain biotechnology software that could be misused for biological weapons purposes. This final rule amends the Export Administration Regulations (EAR) to implement the decision finalized by the Australia Group (AG) on August 6, 2021.…

On August 20, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented additional sanctions on Russia in response to the state-sponsored poisoning of Russian opposition leader Aleksey Navalny in August 2020. Specifically, OFAC has designating nine Russian individuals and two Russian entities found to be involved in Navalny’s poisoning or…

On July 19, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding six Russian entities to the Entity List after having been determined to be “acting contrary to the foreign policy interests of the United States.” The entities are:

  • Aktsionernoe Obshchestvo AST;
  • Aktsionernoe Obshchestvo Pasit;
  • Aktsionernoe Obshchestvo Pozitiv

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