On August 27, 2020 the Department of Commerce’s Bureau of Industry and Security (“BIS”) published a long-awaited advance notice of proposed rulemaking (“ANPRM”) seeking public comment on criteria for identifying “foundational technologies” that are essential to US national security with a view to imposing export controls on such uncontrolled technologies. BIS will use the public comments during the interagency process aimed at developing new export controls on foundational technologies. After the interagency process is finalized, BIS will…
On August 6, 2020, the Federal Emergency Management Agency (“FEMA”) issued a temporary final rule extending and modifying FEMA’s previously imposed restrictions on the export from the United States of certain personal protective equipment (“PPE Products”) used in the response to the COVID-19 pandemic (“Extension Rule”). The original restrictions on exports of PPE Products imposed by FEMA were published on April 10, 2020. The Extension Rule became effective today, August 10, 2020, and will be…
On July 16, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and extended two Ukraine-related general licenses related to GAZ Group (“GAZ”). Notably, General License No. 15I (“GL 15I”), issued to replace General License 15H, authorizes a wider range of activities related to the “the manufacture and sale of existing and new models of vehicles, their components, and spare parts” produced by GAZ. By way of background, GAZ was…
On June 15, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“Interim Final Rule”) effective on June 18, 2020 to authorize the limited release of certain items subject to the Export Administration Regulations (“EAR”) to Huawei and its affiliates listed on the BIS Entity List (“Huawei Listed Entities”) in the context of international efforts to develop technical standards for 5G and other new technologies. In a…