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On Friday, September 16, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule…

U.S. Department of Commerce, Bureau of Industry and Security BIS published in Federal Register Final Rule, 87 Fed Reg. 57068, amending Export Administration Regulations EAR to impose several new controls on exports, reexports, and transfers of items within Russia and Belarus

To embed, copy and paste the code into your website or blog: Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule.   In an interim rule published on, January 15, 2020, the Department of Commerce, Bureau of Industry and Security (BIS), introduced expansive changes to General Prohibition 7 of the Export Administration Regulations (EAR) by including new controls on military-intelligence end uses and users, making the already tricky process of conducting business with foreign entities that much more comp...

In response to a U.S. government consensus that trade with China involves grave national security risks, the Trump Administration promulgated a broad series of China-directed export controls, economic sanctions and import rules. The flow of trade measures became a torrent in the Trump Administration’s final months. This alert briefly surveys key new trade controls from late in the Trump Administration and Chinese policy responses that the Biden Administration inherits. It is not clear that the Biden Administration will prioritize a more regularized trading relationship with China. As it mov...

[co-authors: Nick Russell, and Alasdair Kan] Key Points The U.S. government has recently imposed controls pertaining to “Communist Chinese Military Companies” (CCMCs or “1237 entities”); Chinese “Military End Users” (MEUs); and Chinese “Military-Intelligence End Users” (MIEUs). The U.S. government has also been adding Chinese companies to the Entity List based on concerns regarding the companies’ relationships to the Chinese military industrial complex. Although the names and underlying policy concerns are similar, the scope and source of the prohibitions regarding each set ...