Effective March 10, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule extending through May 15, 2020 the validity 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. (“Huawei”) and 114 of its non-US affiliates designated on the BIS Entity List. The TGL had been set to expire on April 1, 2020.

BIS also issued a final rule requesting comments to assist the US Government in evaluating whether the TGL should continue to be extended and whether any changes are warranted to the TGL. Companies, individuals, and other impacted entities have until March 25, 2020 to comment on the following areas:

  • Possible impacts/costs if the TGL is not extended.
  • What would be required for an industry or organization to no longer require the TGL and the costs associated with such a shift.
  • Potential revisions BIS should consider to enhance effectiveness for both covered transactions and transactions outside of the scope of the TGL.
  • Potential alternatives to the TGL which will facilitate compliance with the restrictions that apply to Huawei and its designated affiliates.

If you wish to submit a comment or have any questions, please contact any member of our Outbound Trade Compliance team.  Please see our prior blog posts on the initial designation of Huawei and sixty-eight of its non-US affiliates to the Entity List on May 16, 2019 here; on the issuance of the original TGL on May 20, 2019 here; on the designation of forty-six additional non-US affiliates of Huawei to the Entity List and on the TGL updates issued on August 19, 2019 here; on BIS’s publication of Huawei-related FAQs on September 9, 2019 here; and on BIS’s previous extension of the TGL here.


Laura Klick is a US-qualified Associate in Baker McKenzie's London office, where she advises on a variety of trade and compliance matters involving US, UK, and EU export controls and economic sanctions. Laura regularly counsels individuals and multinational corporations on compliance, licensing, and enforcement matters involving the US Treasury, State, and Commerce Departments and assists clients in understanding and navigating the complex regulatory regime governing international trade and investment.


Inessa Owens is an associate in the Washington, D.C. office and member of the Firm’s International Trade practice group. She focuses on outbound trade compliance issues, including compliance with the Export Administration Regulations, anti-boycott rules, and economic sanctions administered by the US Treasury Department’s Office of Foreign Assets Control, including those targeting Cuba, Iran, North Korea, Syria, and Russia. She has worked with clients in diverse industries that include finance, pharmaceuticals, and energy.


Ms Stafford Powell advises on all aspects of outbound trade compliance, including compliance planning, risk assessments, licensing, regulatory interpretations, voluntary disclosures, enforcement actions, internal investigations and audits, mergers and acquisitions and other cross-border activities. She develops compliance training, codes of conduct, compliance procedures and policies. She has particular experience in the financial services, technology/IT services, travel/hospitality, telecommunications, and manufacturing sectors.