On Tuesday, the U.S., UK, Australia, Canada, and New Zealand—known as the “Export Enforcement Five” or “E5”—issued joint guidance to industry and academia on how best to identify Russian export control evasion tactics. The E5 coordinates with other members of the Global Export Control Coalition (GECC) on export controls specific to Russia. In addition to
New executive order takes aim at U.S. investment in China, Hong Kong, and Macau
On August 9, 2023, President Biden issued his much anticipated executive order on outbound U.S. investment in China, Hong Kong, and Macau (dubbed “reverse CFIUS”). The Treasury Department simultaneously released an advance notice of proposed rulemaking (ANPRM) related to the order. Public comments on the ANPRM will be accepted until September 28. The final rule
BIS further strengthens antiboycott enforcement efforts
In October, the Bureau of Industry and Security (BIS) strengthened its antiboycott enforcement strategy. Last week, BIS made two additional enhancements to its enforcement strategy:
- New Boycott Request Reporting Form. U.S. persons who receive boycott requests will now be required to identify the requesting party in addition to the country from which the
New Tri-Seal Compliance Note highlights voluntary self-disclosure procedures and benefits
The U.S. Department of Justice (DOJ), Bureau of Industry and Security (BIS), and Office of Foreign Assets Control (OFAC) published their second Tri-Seal Compliance Note on July 26 summarizing their voluntary self-disclosure procedures for export control and sanctions violations. The Note highlights the potential benefits of self-disclosure, including significant mitigation of civil and criminal liability.
Uyghur Forced Labor Prevention Act’s reach extends beyond China
U.S. Customs and Border Protection’s (CBP) statistics confirm that the Uyghur Forced Labor Prevention Act’s (UFLPA) reach extends beyond imports from China. Though importers must remain focused on mitigating UFLPA compliance risks for Chinese-origin goods, CBP’s enforcement statistics offer a broader perspective on the scope of UFLPA-related detentions and seizures.
We highlight key takeaways and
The Court of International Trade upholds Section 301 tariffs on Chinese-origin goods
The Court of International Trade continues to focus in on issues relating to Chinese-origin goods and on March 17 upheld the Section 301 tariffs on Chinese-origin goods identified on List 3 and List 4A. This decision comes despite the plaintiffs in In re Section 301 Cases arguing that the U.S. Trade Representative (USTR) violated the
New CHIPS and Science Act funding has national security stipulations
The U.S Department of Commerce recently released the first of three expected Notices of Funding Opportunities under the CHIPS and Science Act of 2022. This act aims to develop the domestic semiconductor supply chain, provide jobs, restore the country’s leadership in semiconductor manufacturing, and advance U.S. national and economic security.
In our latest alert, found on reedsmith.com
New guidance on detecting sanctions evasion released by U.S. government
A Tri-Seal Compliance Note (“Note”) has been released by the Department of Commerce, Department of Treasury, and Department of Justice to assist businesses in identifying warning signs and implementing appropriate compliance measures to ensure cooperation with Russian-related sanctions and export controls. One of the most common sanction evasion tactics highlighted in the Note is the
New sanctions announced one year on from Ukraine invasion
G7 leaders have announced new economic commitments designed to hold Russia accountable for its war against Ukraine. We discuss these commitments and provide an overview of the latest sanctions imposed on Russia by the United States, European Union, and United Kingdom in our recent alert on reedsmith.com.
U.S. Disruptive Technology Strike Force – how can companies prevent and respond to potential diversion?
The Department of Justice (DOJ) and the Department of Commerce announced the creation of a joint Disruptive Technology Strike Force on February 16, 2023. The strike force will be co-led by the assistant attorney general for the DOJ’s National Security Division and the assistant secretary for export enforcement at the Bureau of Industry and Security.