On July 12, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding thirty-four (34) entities to the Entity List for the following destinations: Canada; People’s Republic of China (China); Iran; Lebanon; Netherlands; Pakistan; Russia; Singapore; South Korea; Taiwan; Turkey; the United Arab Emirates (UAE); and the United Kingdom.
Export Control
BIS Adds Five Chinese Companies to Entity List for Human Rights Violations
Effective June 24, 2021, the Bureau of Industry and Security (BIS) will place five Chinese companies on the Entity List for human rights violations and abuses in the implementation of China’s campaign of repression, mass arbitrary detention, forced labor and high-technology surveillance against Uyghurs, Kazakhs, and other members of Muslim minority groups in the Xinjiang…
OFAC Sanctions Belarusian Individuals and Entities; Issues Belarus General License No. 3
On June 21, 2021, the Office of Foreign Assets Control (OFAC) designated 16 individuals and five entities in response to the Lukashenko regime’s escalating violence and repression. The persons are all closely associated with Belarusian President Alexander Lukashenko and, according to an OFAC press statement, “have harmed the people of Belarus through their activities…
OFAC Authorizes Certain Activities in Iran, Syria and Venezuela to Respond to COVID-19 Pandemic
On June 17, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three general licenses related to the sanctions programs of Iran (General License N), Syria (General License 21) and Venezuela (General License 39), “Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)…
DDTC Proposes to Make Pandemic-Related Telework Rules Permanent
Key Notes:
- Proposed rule would allow persons working under a long-term contract to be considered “regular employees” under the International Traffic in Arms Regulations (ITAR) even if they work remotely.
- Remote work would be permitted so long as people were not working in Belarus, Burma, China, Cuba, Iran, North Korea, Russia, Syria or Venezuela, or
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Transfer of 3D-Printed Gun Technology and Software to the EAR from the ITAR Becomes Final
The State Department’s Directorate of Defense Trade Controls (DDTC) on June 1, 2021 announced that a final rule from January 2020, which moved 3D-printed guns out from control under the International Traffic in Arms Regulations (ITAR) over to the Export Administration Regulations (EAR), is now in effect. See Federal Register notice of January 23, 2020…
BIS Issues FAQs on Foreign Military Sales
On May 12, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a series of Frequently Asked Questions (FAQs) in an effort to respond to numerous questions from industry regarding the export of items that have been moved from the U.S. Munitions List under the International Traffic in Arms Regulations (ITAR) to…
Commerce Issues Fine for Misrepresentations Made in CJ Request
On April 30, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a notice announcing a settlement and fine of over $300,000 to FLIR Systems, Inc. for an egregious violation of the Export Administration Regulations (EAR). This settlement highlights that violations of the EAR are not limited to physical exports of goods…
DDTC Issues Guidance Regarding Restrictions on Exports to Russia
On April 12, 2021, the State Department’s Directorate of Defense Trade Controls (DDTC) issued additional guidance regarding changes that have been made to the International Traffic in Arms Regulations (ITAR) pertaining to export of defense articles or services to Russia. The guidance summarizes changes that were implemented on March 18, 2021, when the Departments of…
BIS Eliminates Most Mass Market Encryption Reporting Obligations
The U.S. Department of Commerce’s Bureau of Industry & Security (BIS) issued a final rule amending the Export Administration Regulations to eliminate most reporting requirements related to open source encryption software and certain “mass market” encryption items and to revise the Commerce Control List.
Key Notes:
- BIS issued a final rule eliminating certain reporting requirements
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