In keeping with tradition, we are pleased to invite you to our annual Global Year-End Review of Import/Export & Trade Compliance Developments Conference. The conference will provide valuable insights on the latest developments, challenges and opportunities in the ever-changing landscape of international trade. We are holding this conference in a split-hybrid format, with an in-person event in Santa Clara, CA, on November 12 and virtual panels on November 19-21. Please see details below. In-Person Event Join us for a crucial…
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (the “IFR”) on September 6, 2024 that imposes new “plurilateral” worldwide licensing controls on certain advanced technologies, including certain quantum, semiconductor-related and additive manufacturing items, under new and amended ECCNs in the Export Administration Regulations (the “EAR”), introduces a new license exception for certain items to allied countries implementing equivalent controls, adds two new general licenses for certain Gate…
In the midst of ongoing sanctions investigations and enforcement actions, companies are faced with yet another challenge: interested third-party stakeholders. Companies must decide who to share information with, what levels and types of information to share, how to share information, and how to mitigate the risks of loss of legal privilege, leaks, and triggering disclosure/reporting obligations by others. In this blog post, the Global Sanctions Investigations Group focuses on three critical third party stakeholders –…
The US Commerce Department’s Bureau of Industry and Security (“BIS”) has issued a final rule (“Final Rule”), effective July 23, 2024, expanding the jurisdictional scope of the Export Administration Regulations’ (“EAR”) Iran Foreign Direct Product Rule (“Iran FDP Rule”) over more foreign-made items and imposing a licensing requirement for the in-country transfer within Iran of items subject to the EAR under the Iran FDP Rule. This expansion of controls was made to implement the requirements…