On September 11, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis detailing trends in suspected evasion of export controls on Russia. FinCEN’s analysis is informed by reports provided by financial institutions under the Bank Secrecy Act (BSA),
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U.S. Bureau of Industry and Security Creates Option for Extended Renewals of Temporary Denial Orders
On August 30, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to allow for the extended renewal of Temporary Denial Orders (“TDOs”) under certain circumstances. Those named by a TDO face…
Commerce Proposes Revisions to Section 232 Steel and Aluminum Tariff Exclusions Process
Deadline of October 12th to Submit Comments
On August 28, 2023, the U.S. Department of Commerce (“Commerce”) published in the Federal Register a proposed rule that makes certain revisions to the Section 232 steel and aluminum tariff exclusions process. The…
Expansion of UFLPA Entity List and Publication of 2023 UFLPA Strategy Updates
By Maliha Khan
On August 1, 2023, the interagency Forced Labor Enforcement Task Force (“FLETF”), led by the U.S. Department of Homeland Security (“DHS”), shared publicly the 2023 updates to the Uyghur Forced Labor Prevention Act (“UFLPA”) Strategy to Prevent the Importation of…
New Nuclear Nonproliferation Controls on China and Macau
On Monday, August 14, 2023, the Commerce Department will impose new nuclear nonproliferation (“NP”) controls on China and Macau. The new controls are meant to address ongoing U.S. Government concerns regarding U.S. nuclear technology and material being diverted to China…
White House Issues Executive Order on Outbound Investment Screening
On August 9, 2023, the White House issued Executive Order 14105 (“EO”) to address the national security threat posed by outbound investment in certain countries of concern that seek to develop and exploit sensitive or advanced technologies and products critical…
Treasury Department Releases 2022 Annual CFIUS Report
On July 31, 2023, the U.S. Treasury Department released its Annual Report to Congress on the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”), covering the 2022 calendar year (the “Report”). The Report highlights key statistics…
Federal Agencies Publish Tri-Seal Official Guidance on Voluntary Self-Disclosure of Violations
On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) released a joint compliance note summarizing the…
Commerce Continues its Focus on Antiboycott Compliance
On July 26, 2023, Matthew Axelrod, the Assistant Secretary for Export Enforcement, issued a memorandum on “Strengthening Antiboycott Reporting and Compliance.” The memorandum announced two new measures. First, the Commerce Department is amending the boycott reporting form to require U.S.…
USITC Releases First Biennial Report on Economic Impact and Operation of USMCA Automotive Rules of Origin
On June 30, 2023, the U.S. International Trade Commission (ITC) released its first report on the economic impact of the United States-Mexico-Canada (USMCA) automotive rules of origin. Rules of origin (ROOs) are used to determine the national origin of a…