Export Control

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On April 7, 2020, the U.S. Department of Homeland Security’s Federal Emergency Management Agency (FEMA) issued a temporary final rule (“Rule”) to establish export restrictions on certain types of personal protective equipment (PPE) products and respirators (“Covered Products”) used in the response to the COVID-19 pandemic. The Rule implements the presidential memorandum dated April 3,…

On April 17, 2020, the Federal Emergency Management Agency’s (FEMA) filed a notification of exemptions (the “Exemptions”) that identifies 10 exemptions from the temporary final rule published on April 10, 2020 (the “Rule”), which restricts the export from the United States of certain personal protective equipment (PPE) and respirators in the response to the COVID-19…

On April 16, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a fact sheet noting that the sanctions programs it administers generally allow for legitimate humanitarian-related trade, assistance or activity under existing laws and regulations. The fact sheet provides consolidated guidance highlighting the most relevant exemptions, exceptions and authorizations for…

Please join us for a webinar on Thursday, April 30 from noon to 1:15 p.m. ET discussing the impact of the COVID-19 pandemic on international trade. During the webinar we will discuss:

  • U.S. and foreign government restrictions on the export of personal protective equipment (PPE)
  • Impact on U.S. customs duties
    • Section 301 tariff product exclusions

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has published amendments in the Federal Register to the North Korea Sanctions Regulations, 31 C.F.R. 510.101-.901 (NKSR), which became effective April 10, 2020. The new amendments incorporate into the NKSR certain provisions of the North Korea Sanctions and Policy Enhancement Act of 2016…

Despite a tightening of economic sanctions on Venezuela under President Donald Trump, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) occasionally issues General Licenses clarifying, authorizing or exempting certain U.S. activities involving the Venezuelan government  or entities directly and indirectly affiliated with Petróleos de Venezuela, S.A (PdVSA).  Starting in January 2019, President…

On April 7, 2020, the U.S. Department of Homeland Security’s Federal Emergency Management Agency (FEMA) issued a temporary final rule to establish export restrictions on certain types of personal protective equipment products (PPE) used in the response to the COVID-19 pandemic.

Key Notes:

  • Effective April 7, 2020, most exports from the United States of certain

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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…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the extension of a general license involving Nynas AB, General License 13E, through 12:01 a.m., May 14, 2020. The announcement explained that OFAC was extending the expiration date of this general license to provide additional time for Nynas AB to complete its…

Effective on March 25, 2020, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) interim final rule amended the “Encryption Rule” under the International Traffic in Arms Regulations (ITAR) (22 C.F.R. § 120.54) with definitions more clearly explaining activities that are not considered to be exports, reexports, retransfers or temporary imports of secured…