On March 2, 2021, the Departments of Commerce, State and the Treasury imposed sanctions and export restrictions on numerous Russian officials and government entities in response to the Russian Federation’s imprisonment and alleged previous poisoning of opposition figure Aleksey Navalny. These actions follow similar sanctions imposed by the European Union and the United Kingdom. Dozens
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BIS Issues Interim Final Rule Expanding Certain Controls on Activities of U.S. Persons
On January 15, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule implementing further provisions of the Export Control Reform Act of 2018 by: (i) imposing additional export license requirements under the Export Administration Regulations (EAR) in connection with certain military-intelligence end uses and end users; (ii) clarifying…
USTR Continues to Criticize China and Russia for Poor WTO Compliance
On January 15, 2020, the Office of the U.S. Trade Representative (USTR) released its annual reports submitted to Congress that assess China’s and Russia’s implementation of their World Trade Organization (WTO) commitments. In keeping with past annual USTR reports during the administration of President Donald Trump, the reports note that these countries’ records of compliance…
Commerce Adds and Removes Entities on Entity List and the MEU List
On January 14, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice announcing the addition and removal of certain Chinese and Russian entities from the Entity List and the Military End-User (MEU) List.
Notably, BIS added China National Offshore Oil Corporation Ltd. to the Entity List for its…
Commerce Issues Military End User List for Exports to China and Russia
On December 23, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice in which it amends the Export Administration Regulations (EAR) by adding a new Military End User (MEU) List. This list identifies entities that BIS has determined are military end users for purposes of the “military end…
State Department Imposes Export and Other Restrictions on Chinese and Russian Entities for Transfers of Controlled Items to Iran, North Korea and Syria
On November 25, 2020, the State Department issued a Federal Register Notice announcing the imposition of nonproliferation measures against certain Chinese and Russian entities for the transfer of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the…
BIS Draft Rule Reportedly Lists, and May Further Restrict Exports with, Chinese and Russian Companies with Military Connections
In an early confidential draft of a proposed rule that BIS has shared with a technical advisory committee of industry representatives, trade press is reporting that the Department of Commerce’s Bureau of Industry and Security (BIS) may seek to restrict export transactions with 89 Chinese and 28 Russian companies that are owned or controlled by…
Government Measures Taken in Response to COVID-19: Country-by-Country Guide 2.0
Since April 2020, we have collaborated with our foreign law firm partners to provide a chart summarizing the economic, labor and employment, health and safety, and export and import measures taken by governments around the world in response to the COVID-19 pandemic. After a short break, we are back with version 2.0 of our chart…
Commerce Further Revises License Review Policy for Certain Exports to China, Russia and Venezuela
On October 29, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice announcing further amendments to the Export Administration Regulations (EAR) to revise the license review policy for items controlled for national security reasons destined to the People’s Republic of China (PRC), Venezuela or the Russian Federation (Russia).…
Department of Commerce Adds 60 Companies to the Entity List, Including 24 Chinese Companies, for Involvement in Militarizing the South China Sea
On August 26, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was adding 24 Chinese companies to the Entity List for their role in helping the Chinese military construct and militarize the internationally condemned artificial islands in the South China Sea. “The United States, China’s neighbors, and the international…

