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US Export Controls

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On March 18, 2021, the US State Department (“State”) published in a Federal Register notice that formally outlines the various US export controls targeting Russia that will be strengthened pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (“CBW Act”) as a result of State’s determination that the Russian Government had used a chemical weapon against its own nationals in violation of international law. These measures were previously announced by…

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 31, 2020, the Federal Emergency Management Agency (“FEMA“) issued a temporary final rule extending and modifying export restrictions on certain types of medical supplies and personal protection equipment products (“PPE Products”) used in response to the COVID-19 global health pandemic. The new rule became effective December 31, 2020; extends previously-imposed export restrictions on covered PPE Products to June 30, 2021; and adds certain types of syringes and needles to the list of covered PPE…

On December 22, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) in the Federal Register adding 77 entities and individuals to the Entity List, including several prominent Chinese multinationals (together, the “Designees”). The Final Rule took effect on December 18, 2020. On the same day, BIS also published FAQs related to its recent expansion of the foreign-produced direct product rule (the “Huawei FPDP Rule”). Entity List Designations In press…