Author

Inessa Owens

Browsing

As of May 1, the State Department has made a temporary change in the Tier I, Tier II, and new registrant payment guidelines on the Directorate of Defense Trade Controls (“DDTC”) website to reflect certain reduced registration fees to mitigate the economic impact of the COVID-19 pandemic. The DDTC is reducing fees for Tier I and Tier II registrants to $500 (reduced from $2,250 and $2,750, respectively) for registrations whose original expiration date is between…

On April 21, US Customs and Border Protection (“CBP”) issued guidance via a bulletin in its Cargo Systems Messaging Service (available here) (“Bulletin”) on the new temporary final rule published by the Federal Emergency Management Agency (“FEMA”) imposing export restrictions on certain personal protective equipment products (“PPE Products”) used in the response to the COVID-19 pandemic. The Bulletin details CBP’s implementation of the PPE export restrictions and its process for determining whether an export may be covered by…

The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”). OFAC CMP Adjustments Under OFAC’s final rule published on April 9, 2020, the adjusted penalties apply to CMPs that are assessed after April 9, 2020, as long as the violation occurred after November…

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…