On April 8, 2022, in response to Russia’s ongoing aggression in Ukraine, which has been substantially enabled by Belarus, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) expanding license requirements for Russia and Belarus under the Export Administration Regulations (“EAR”) to all items on the Commerce Control List (“CCL”). The Final Rule also removes license exception eligibility for aircraft registered in, owned or controlled by, or under charter or…
As flagged in our initial blog, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published on February 24, 2022 a public inspection copy of a final rule (“Final Rule”), effective immediately (subject to a very limited savings clause), that implements a sweeping series of export control measures under the Export Administration Regulations (“EAR”) against Russia. The press release regarding these new controls can be found here. The controls are a result of multi-laterally coordinated efforts…
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”), as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule published on February 9, 2022, the adjusted penalties apply to CMPs…
On January 26, 2022, the US Departments of State, Treasury, Commerce, Labor, Homeland Security and the Office of the US Trade Representative (“USTR”) issued a joint advisory (the “Advisory”) cautioning businesses, financial institutions, investors, consultants, research service providers, etc. of the heightened risks associated with doing business in Burma/Myanmar, especially wherever the Myanmar military is involved. This is a continuation of US Government’s actions to address the situation in Myanmar. Please see our blog posts…