Inessa Owens


Effective March 10, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule extending through May 15, 2020 the validity of the Temporary General License (“TGL”) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations (“EAR”) to Chinese-headquartered Huawei Technologies Co. Ltd. (“Huawei”) and 114 of its non-US affiliates designated on the BIS Entity List. The TGL had been set to expire on…

On February 24, 2020, in a final rule (the “Rule”) that took immediate effect, the Commerce Department’s Bureau of Industry and Security (“BIS”) revised the country group designations for Russia and Yemen under the Export Administration Regulations (“EAR”), increasing license restrictions for both countries. The Rule is part of a larger effort within BIS that involves a “comprehensive review” of all country groups to ensure they appropriately reflect current US national security and foreign policy.…

On January 10, 2020, the US Department of
Transportation (“DOT”) issued an order
imposing new restrictions on public charter flights from the United States to
Cuba. While certain US
restrictions on Cuba, including for travel, were relaxed under President Obama,
the Trump Administration has gradually rolled back some of these changes and
further tightened US travel restrictions vis-à-vis Cuba.

On December 13, 2019, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”) released a revised policy regarding voluntary self-disclosures of willful export control and sanctions violations (the “Policy”).  The Policy reiterates DOJ’s commitment to pursue willful violations of export control and sanctions violations, and supersedes the DOJ’s “Guidance Regarding Voluntary Self-Disclosures, Cooperation, and Remediation in Export Control and Sanctions Investigations Involving Business Organizations,” dated October 2, 2016 (“2016 Guidance”).

The Policy clarifies the requirements for companies seeking to receive credit for voluntary self-disclosures (“VSD”) of willful export control or sanctions violations, and sets forth the potential benefit to companies who meet the requirements set forth in the Policy.