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EAR

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The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued two proposed rules amending the Export Administration Regulations (“EAR”) to impose expansive new controls on US persons’ activities in connection with non-US military, security, and intelligence end users and end uses, as well as new end user-, end use-, and list-based controls applicable to items subject to the EAR. These new controls would apply to more categories of activities and end users/end…

The US Commerce Department’s Bureau of Industry and Security (“BIS”) has issued a final rule (“Final Rule”), effective July 23, 2024, expanding the jurisdictional scope of the Export Administration Regulations’ (“EAR”) Iran Foreign Direct Product Rule (“Iran FDP Rule”) over more foreign-made items and imposing a licensing requirement for the in-country transfer within Iran of items subject to the EAR under the Iran FDP Rule. This expansion of controls was made to implement the requirements…

The US Commerce Department’s Bureau of Industry and Security (“BIS”) has issued amendments to the Export Administration Regulations, 15 C.F.R. Parts 730-774 (“EAR”) that, most significantly, define the scope of “standards-related activities” that are subject to US export controls jurisdiction under the EAR. The purpose of these amendments is to ensure that US export controls and associated compliance concerns do not impede the participation and leadership of US companies in legitimate standards-related activities. BIS also…

On June 12, 2024, the US Departments of Treasury and Commerce issued new sanctions and export controls in response to Russia’s continued war in Ukraine. Below we outline key categories of these new and expanded trade measures designed to restrict the flow of support to the Russian military-industrial base. The new sanctions issued by the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) are directed at Russia’s foundational financial infrastructure and access to…