On January 16, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule (the “IFR”) revising the Export Administration Regulations (“EAR”) to impose new controls on certain biotechnology equipment and related technology. As stated in the IFR, the new controls are necessary to protect against US national security and foreign policy interests “given the dual-use nature and relevance of specific biotechnology equipment to contribute to the research and development…
Shortly after taking the oath of office today, newly inaugurated President Trump signed a flurry of Executive Orders (“EOs”) and other executive actions. This include several actions related to US sanctions and export controls. Authority to Designate Cartels as Foreign Terrorist Organizations or Specially Designated Global Terrorists Trump signed an EO Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists. This EO creates a legal authority to designate certain international…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State (“State”), the US Department of Commerce (“Commerce”), and the US Department of Energy (“DOE”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule issued on January 15, 2025,…
On January 2, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an advance notice of proposed rulemaking (“ANPRM”) seeking public comments to inform the potential development of a rule to safeguard the information and communications technology and services (“ICTS”) supply chain for unmanned aircraft systems (“UAS”), pursuant to the authority of Executive Order 13873. This follows other recent developments in the ICTS regime, including the December 6, 2024 Final Rule amending…