On June 11, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published in the Federal Register the List of Medical Devices Requiring Specific Authorization under the North Korea Sanctions Regulations, 31 CFR Part 510 (“NKSR”). The export or reexport of these excluded non-US medical devices to North Korea requires a specific license from OFAC if US Persons are involved. Other non-US medical devices remain eligible for export/reexport to North Korea…
On May 31, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance clarifying that a license continues to be required under the Export Administration Regulations (“EAR”) for exports of advanced computing items to entities located in any country, if those entities are headquartered in Country Group D:5 (including China) or Macau, or have “an ultimate parent company” headquartered in Country Group D:5 or Macau. The BIS Guidance was prompted by…
On April 17, 2026, the Office of Management and Budget (“OMB”) issued Memorandum M‑26‑11 announcing that there will be no annual inflation adjustment to federal civil monetary penalties (“CMPs”) for the calendar year 2026. (For prior annual CMP adjustments, see our previous blog post available here and here.) The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (the “Act”) mandates annual adjustments to CMPs across the federal government, including CMPs administered by the Department…
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule, effective January 15, 2026, revising the license review policy for exports from the United States of certain commercially available advanced computing semiconductors to end users in China and Macau—moving from a presumption of denial to case‑by‑case review under certain conditions. The case-by-case review policy is only available for exports meeting strict requirements, including various certifications as to sufficient supply…