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BIS to Publish Rule Suspending License Exceptions for Hong Kong under Export Administration Regulations

By Brian Egan, Ed Krauland & Meredith Rathbone on July 30, 2020
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On July 31, The Commerce Department’s Bureau of Industry and Security (BIS) will publish a notification in the Federal Register amending the Export Administration Regulations (EAR) to suspend the availability of all License Exceptions for Hong Kong that provide differential treatment as compared to those available to China.  This EAR change implements the announcement made on BIS’s website on June 30, 2020 that these License Exceptions are no longer available for exports and reexports to Hong Kong, and transfers within Hong Kong, of all items subject to the EAR.  To implement the change, BIS is adding a new, Hong Kong-specific paragraph to EAR Section 740.2 (“Restrictions on all License Exceptions”), as well as making some other conforming changes to Section 740.2.

BIS is taking this action as part of revised U.S. policy toward Hong Kong in response to the newly imposed security measures on Hong Kong by China.  Although the Federal Register notice does not make other changes to the EAR regarding Hong Kong or China, the notice indicates that BIS, in consultation with other executive branch agencies, continues to review the EAR to assess whether additional amendments are warranted.

Photo of Brian Egan Brian Egan

Brian Egan advises on a number of international legal issues that affect US and foreign clients, including economic sanctions, export controls, and anti-money laundering programs; national security trade and investment reviews; international arbitration and other cross-border disputes; international cybersecurity and data privacy; and…

Brian Egan advises on a number of international legal issues that affect US and foreign clients, including economic sanctions, export controls, and anti-money laundering programs; national security trade and investment reviews; international arbitration and other cross-border disputes; international cybersecurity and data privacy; and issues of public international law. He has worked in various senior legal positions for the US government, giving him keen insight into domestic and international legal matters that influence US government national security and foreign relations policies and programs. Before joining Steptoe, Brian served as the Legal Adviser to the US Department of State, the Legal Adviser to the National Security Council, Deputy White House Counsel, and Assistant General Counsel for Enforcement and Intelligence with the US Department of the Treasury. Brian has regularly appeared in public fora to speak on international legal issues, including testifying before Congress, public speaking engagements, and panel presentations.

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Photo of Ed Krauland Ed Krauland

Edward J. Krauland focuses on export controls/economic sanctions. Ed’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of…

Edward J. Krauland focuses on export controls/economic sanctions. Ed’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of government procurement regulations in the cross-border context. His practice spans all aspects of these laws, including counseling, compliance work, transactional advice, licensing and opinion work, internal reviews, disclosures, and enforcement actions. He has served as co-chair of the International Trade Committee of the ABA Section of International Law and Practice. He is former Chairman of an ABA-wide Task Force on Gatekeeper Regulation (anti-money laundering compliance), and senior adviser to the ABA Section of International Law and Practice’s anti-money laundering committee.

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Photo of Meredith Rathbone Meredith Rathbone

Meredith Rathbone focuses on export controls and economic sanctions, and has assisted clients in the energy, manufacturing, telecommunications, information security, banking, insurance, pharmaceutical, and service industries, among many others, in navigating the requirements of the Export Administration Regulations (EAR), International Traffic in Arms…

Meredith Rathbone focuses on export controls and economic sanctions, and has assisted clients in the energy, manufacturing, telecommunications, information security, banking, insurance, pharmaceutical, and service industries, among many others, in navigating the requirements of the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR) and US sanctions regulations administered by the Office of Foreign Assets Control (OFAC) and US Department of State. She regularly assists companies in developing compliance policies, conducting internal investigations, performing training, and conducting due diligence in M&A transactions. She has represented individuals and companies facing civil and criminal investigations in this area, and has also represented clients in their efforts to be removed from OFAC’s list of Specially Designated Nationals (SDNs). She is a frequent writer and speaker on export controls and sanctions topics. She is the co-chair of the American Bar Association’s Export Controls and Economic Sanctions Committee, and also serves on the Sanctions Subcommittee of the State Department’s Advisory Committee on International Economic Policy.

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  • Posted in:
    Administrative and Regulatory
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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