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
Export Control
U.S. Aid Package for Ukraine, Israel and the Indo-Pacific Incorporates Extensive Sanctions and Export Control Reforms
On April 24, 2024, President Biden signed into law a broad national security package which included the Israel Security Supplemental Appropriations Act, 2024; Ukraine Security Supplemental Appropriations Act, 2024; Indo-Pacific Security Supplemental Appropriations Act, 2024; 21st Century Peace through Strength Act; FEND off Fentanyl Act; and the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act.
Further AUKUS Progress: State Publishes Proposed Rule for License Exemptions for Australia and the United Kingdom
On May 1, 2024, the State Department published a proposed rule to amend the International Traffic in Arms Regulations (ITAR) and establish an exemption to the licensing requirement for exports, reexports, transfers, or temporary import of defense articles to or within Australia and the United Kingdom. This proposed rule is intended to promote the goals…
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…