The US Commerce Department’s Bureau of Industry and Security (“BIS”) is extending the comment period for future extensions of the temporary general license (“TGL”) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations (“EAR”) to Chinese-headquartered Huawei Technologies Co. Ltd. and its non-US affiliates designated on the BIS Entity List.  Parties now have until April 22, 2020 (extended from March 25, 2020) to submit comments.  BIS is soliciting comments on, among other things, whether the TGL should continue to be extended, whether any other changes should be made to the TGL, and whether there are any alternative authorization or other regulatory provisions that may more effectively address what is being authorized under the TGL.  Our previous blog post issued at the start of the comment period can be found here.  If you wish to submit a comment or have any questions, please contact any member of our Outbound Trade Compliance team.

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Mr. Coward focuses on outbound trade compliance matters, including the extraterritorial application of US law, particularly US export control laws, anti-boycott regulations and trade sanctions/embargoes maintained by the US government against various countries. In addition, his practice covers issues of corporate conduct such as the application of the Foreign Corrupt Practices Act and foreign bribery laws. He provides international transactional advice; assistance in the design and implementation of corporate compliance programs, compliance audits, and internal investigations; and representation in enforcement proceedings.

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Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.

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