On April 17, 2020, the Federal Emergency Management Agency (āFEMAā) filed a notification of exemptions (the āFEMA Notificationā) in the Public Inspection List that identifies 10 exemptions from the temporary final rule published on April 10, 2020 (the āFEMA Ruleā), which restricts the export from the United States of certain personal protective equipment (āPPE Productsā) used in the response to the COVID-19 pandemic. Although the FEMA Notification will not be published in the Federal Register until Tuesday,…
On April 9, 2020, US Customs and Border Protection (āCBPā) issued internal guidance (available here as of April 14, 2020) (āGuidanceā) to CBP Field Operations Directors on CBPās implementation of the new temporary final rule published by the Federal Emergency Management Agency (āFEMAā) imposing export restrictions on certain personal protective equipment products (āPPE Productsā) used in the response to the COVID-19 pandemic (the āFEMA Ruleā). Specifically, the Guidance describes which products and shipments are targeted…
Maria Sergeyeva recently authored the blog post “Industry Groups Push Back on Commerce Departmentās Proposed Supply Chain Regulations That Could Block or Restrict Tech Transactions” for Baker McKenzie’s Global Supply Chain Compliance blog.Ā The post highlights concerns expressed by many trade associations and businesses with the highly anticipated proposed regulations issued by the US Department of Commerce to implement Executive Order 13873, āSecuring the Information and Communications Technology and Services Supply Chain.āĀ Executive Order 13873…
On February 24, 2020, in a final rule (the “Rule”) that took immediate effect, the Commerce Departmentās 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.…