On July 10, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance on addressing the risks of diversion of items subject to US export controls to countries or parties of concern (the “Guidance”). The Guidance summarizes mechanisms that BIS uses to notify companies and universities about parties that present diversion risks and that do not appear on its screening lists, as well the level of due diligence BIS expects in…
On July 1, 2024, the Italian Ministry of Foreign Affairs adopted a Decree establishing the National Control List for dual-use goods and technology not listed in Annex I to Regulation (EU) 2021/821 (the “EU Dual-Use Regulation”). This new list supplements and goes beyond controls under the EU Dual-Use Regulation. With respect to the newly listed items, the Italian Government has introduced unilateral authorization requirements not only for their export from the Italian territory to non-EU…
On June 19, 2024, Global Affairs Canada issued a Notice to Exporters regarding regulatory amendments to the Export Control List (ECL) that were previously approved by an order-in-council (Order) on May 31, 2024 (Amendments). The Amendments target goods and technology in relation to quantum computing and advanced semiconductors, following similar unilateral amendments (or proposed amendments) to export controls implemented in the UK, France, Spain and Finland. Exports from Canada of the goods/technology subject to the…
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. New Sanctions Restrictions 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…