In keeping with tradition, we are pleased to invite you to our annual Global Year-End Review of Import/Export & Trade Compliance Developments. This year, we are excited to provide a virtual offering available to all our clients and friends worldwide, plus an in-person reception and networking event for local attendees! The conference will be comprised of 75 minute virtual sessions over the course of three days. Please join us on November 15, 16 and 17 for any or all sessions. The in-person reception…
On February 3, 2022, the Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule reorganizing, clarifying, and correcting the traditional and Entity List foreign-direct product rules (“FDP Rules”) in the Export Administration Regulations (“EAR”). This rule does not change the substantive scope of the FDP Rules, but provides certain helpful clarifications. We previously blogged about the FDP Rules here. Reorganization: Consolidation of the FDP Rules into EAR Part 734.9 The FDP Rules…
Under the Russian encryption regulations, notification to, or registration with, the Russian Federal Security Service (the “FSB”) is required in order to import and distribute foreign products (hardware and software) with encryption functions or features in the Russian Federation. Although the FSB is a sanctioned party, listed on the Office of Foreign Assets Control (“OFAC”) list of specially designated nationals and blocked persons (the “OFAC SDN List”) pursuant to the Cyber-Related Sanctions Regulations, 31 C.F.R.…