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As a follow-on to last week’s quint-seal guidance, the Bureau of Industry and Security (BIS) published best practice guidance to help prevent high-priority items from being diverted to Russia. The latest guidance focuses on exports of the following high-priority items to counterparties in countries outside the Global Export Controls Coalition (GECC):[1]

HS Code

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

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

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

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.

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

In coordination with the G7 and other international partners, the U.S. implemented new Russia-related sanctions and export controls on May 19, 2023. The U.S. also released an additional select list of potential export control evasion “red flags.”

Restrictive economic measures

The Office of Foreign Assets Control (OFAC):

  • Sanctioned 22 individuals and 104 entities in more

The Civil Rights Division of the Department of Justice has issued guidance clarifying that when a position requires access to export-controlled information or items, that requirement is not a basis for making an employment decision based on citizenship, immigration status, or national origin.

In our recent alert on reedsmith.com, we examine U.S. export control

The Bureau of Industry and Security (BIS) has clarified two enforcement policies in an attempt to incentivize voluntary self-disclosures and disclosures about others’ possible violations of the Export Administration Regulations (EAR).

In our recent post, we consider the implications of this latest development.

An alert was issued by the U.S. Office of Foreign Assets Control (OFAC) on April 17 warning about the potential evasion of the Russian-origin oil price cap. The alert came after OFAC had received reports that oil exported from the Eastern Siberia Pacific (ESPO) pipeline or ports on Russia’s eastern coast was trading above the