New Sanctions Imposed on Elements in the Turkish Government
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United States Ramps Up Sanctions Pressure on Russia and Venezuela
Over the course of the last week, the United States has escalated its sanctions programs targeting Russia and Venezuela. It began by implementing the long-delayed second round of sanctions on Russia mandated by the Chemical and Biological Weapons Act of 1991 (CBW Act) on Saturday, August 3, 2019. While the CBW sanctions will have a limited impact on most companies, the same cannot be said of the issuance of Executive Order 13884 (“E.O. 13884”) on…
Identifying and Defining “Emerging Technologies” Subject to Control for Export and Foreign Investment
On November 19, 2018, the Bureau of Industry and Security (BIS) published an advance notice of proposed rulemaking (ANPRM) seeking comments on implementation of Section 1758 of the Export Control Reform Act of 2018. This section requires Commerce, in consultation with DoD and other CFIUS member agencies, to define “emerging technologies” sufficiently significant to U.S. national security interests to impose some level of export controls over the technology and potentially to trigger mandatory declarations of…
United States Reinstates Full Iran Embargo
On November 5, 2018, in accordance with President Trump’s May 8, 2018 decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an amendment to the Iranian Transactions and Sanctions Regulations (ITSR). The amendment followed on the expiration of the final 180-day wind-down period for transactions previously authorized by “General License H” and for the re-imposition of the remaining “secondary sanctions,” which…
DDTC Requests Industry Testing for New Registration and Advisory Opinion Applications
The Directorate of Defense Trade Controls (DDTC) announced this week that it will post test versions of its new Registration and Advisory Opinion (AO) applications on the cloud-based Defense Export Control and Compliance System (DECCS) for industry testing and feedback starting October 16th through mid-November 2018.
If a company is interested in participating in this testing, DDTC asks to please contact the DDTC Test Support Team at the number or email below to sign up…
U.S. National Security Review of Foreign Investment: Revisions to CFIUS Legislation Signed Into Law
On August 13, 2018, the President signed the National Defense Authorization Act for Fiscal Year 2019 which includes the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) updating national security reviews performed by the Committee on Foreign Investment in the United States (CFIUS).
Some FIRRMA provisions are effective immediately, but the effective date of others requires formal rulemaking to be completed within the next 18 months. Included in the provisions effective immediately is a…
Plugging the “Gaps” on Transfers of U.S. Sensitive Emerging Technology: Dual-Use Export Control Statutory Authority Becomes Law
ZTE Back in Business as Commerce Department Lifts Denial Order
In a July 13, 2018 press release, the Commerce Department announced it had lifted the denial order on Zhongxing Telecommunications Equipment Corporation, of Shenzhen, China (ZTE Corporation) and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (ZTE Kangxun) (collectively, ZTE). Commerce took this action shortly after ZTE deposited $400 million in escrow at a U.S. bank to provide a form of security that ZTE will comply with its continuing obligations under the June 2018…
“America First” Moves to Export Controls: New Bill Introduced in House
On February 15, 2018, Representative Ed Royce, Chairman of the House Foreign Affairs Committee, introduced new legislation intended to “modernize U.S. export control regulations of dual-use items.”
In spite of its title, the Export Control Reform Act of 2018 (H.R. 5040) does little to further the original goals of the Export Control Reform initiative and appears more squarely focused on using the Export Administration Regulations to prevent U.S. adversaries — principally the PRC — from…
Supply Chain Corner: Blockchain and Your Supply Chain, U.S. Forced Labor Update, and North Korea and Forced Labor
Blockchain and Your Supply Chain
Since our previous Client Alert, distributed ledger technology (DLT), also known as “blockchain,” has continued to find new applications in supply chain security and documentation. DLT provides an “append only” chain of transaction documentation that can be shared widely or narrowly to provide a strong record for import and export supply chain records. A number of high profile announcements illustrate the resources being devoted to DLT and supply chains.…