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EAR

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On January 14, 2021, the US Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to remove Sudan’s designation as a State Sponsor of Terrorism (“SST”) (the “Amendments”). The Amendments implement the rescission of Sudan as an SST as announced by the Trump Administration in December 2020 by removing Anti-Terrorism (AT) and related controls on Sudan, which had remained in force following the US Government’s revocation of comprehensive sanctions in…

On January 15, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule (“Rule”) amending various provisions of the Export Administration Regulations (“EAR”) to implement certain provisions of the Export Control Reform Act of 2018 (“ECRA”). Among other things further outlined below, the Rule imposes new restrictions on specific activities of US persons. By way of brief background, the EAR generally controls transactions involving US origin items (i.e., goods, software, technology)…

On January 12, 2021, the US Department of Commerce issued a final rule (the “Final Rule”) amending the Export Administration Regulations (“EAR”) to implement recent licensing review policy changes for exports of US-origin unmanned aerial systems (“UAS”), also known as “drones.” Our prior blog posts on UAS export policy developments are available here and here. The Final Rule implements the more flexible export license review policy applicable to a specific subset of UAS with maximum…

On December 28, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) to revise the Country Group designations for Ukraine, Mexico, and Cyprus. BIS has placed these countries’ into more permissive Country Groups due to these countries’ membership in multilateral export control regimes, as well as national security interests and policies compatible with those of the United States. The impact of these…