This week of September 16, Paris will play host to the biggest spectacle of the year (sorry, Olympics), the World Space Business Week. Attendees will come from around the world to discuss advancements in commercial space and global satellite infrastructure. However, it will be the representatives of Australian, UK, and U.S. companies that may have ..read more

On July 29, 2024, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) proposed a series of transformative new rules aimed at tightening controls related to military, intelligence, and security activities under the Export Administration Regulations (EAR). These proposed changes are set to impact how businesses manage exports and interact with end users ..read more

On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten years. OFAC expects to publish an interim final rule to provide an opportunity to comment. The change will increase compliance obligations for ..read more

As the Committee on Foreign Investment in the United States (CFIUS) continues to expand its jurisdictional reach, investors, property owners, and landlords should be aware of a growing focus on real estate transactions. Bridging a perceived gap between CFIUS’ mandate to safeguard U.S. national security and foreign investment in the U.S. real estate market, the ..read more

Effective July 10, 2024, President Biden issued two Presidential Proclamations aimed at refining the tariff exclusions under Section 232 of the Trade Expansion Act of 1962 for steel and aluminum imports from Mexico. Together, the Proclamations close loopholes whereby steel and aluminum from outside North America could avoid tariffs by shipping through Mexico. Those Proclamations reflect a concerted effort between the United States and Mexico to refine tariff exclusions, enhance regulatory oversight, and ensure compliance with international trade agreements. Importers of steel and aluminum now ..read more

As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide. That guide, which was last updated in March 2024, includes numerous case examples illustrating BIS’s criminal and administrative enforcement actions. The update also comes with two additional BIS publications addressing measures to reduce diversion risks and a six-year review of BIS’s licensing strategy. No need to worry—we’ve summarized all the key points for you below. Th ..read more

On June 27, 2024, the U.S. Department of Commerce, Bureau of Industry & Security (BIS) announced its first update to the boycott requester list. The list contains entities that have been reported by a U.S. person as having made a boycott-related request in connection with a transaction in the interstate or foreign commerce of the United States. The latest update adds 57 entities to the list and removes 127 entities. Some notable additions include entities from Japan and Germany. Background On March 28, 2024, BIS personnel announced the rollout of a boycott requester list. The announcement ..read more

The U.S. State Department has proposed amendments to the International Traffic in Arms Regulations (ITAR) to increase the fees required for Directorate of Defense Trade Controls (DDTC) registration. The ITAR requires persons engaging in manufacturing, exporting, temporarily importing, or brokering of any defense articles or services register with DDTC. This proposed rule marks the first adjustment to the registration fee structure in over fifteen years. The revisions are intended to better align the fees with the current operational costs of the DDTC and to support enhancements of the services ..read more

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel kitchen sinks are officially prohibited for export to Russia and Belarus. In our recent blog article on Russia Sanctions, we noted that the U.S. Office of Foreign Assets Control (OFAC) beefed up its sanctions against Russia’s financial infrastructure. That same day, the Bureau of Industry and Security (BIS) also unveiled a draft regulation of its own on Russia. Those BIS regu ..read more

The solar industry is starting to get whiplash. Over the past year in particular, the industry has experienced a whirlwind of regulatory changes making solar tariffs some of the most complex tariffs in all of U.S. importing history. We should not expect the changes to lessen as the solar industry remains a focus for policymakers, industry stakeholders, and consumers. Given this frenetic pace (plus the upcoming June 28 deadline for public comments on the recent Section 301 duty increases), we provide this guide to current tariff and trade actions as a guide to help those in the industry keep af ..read more