The Bureau of Industry and Security (BIS) is seeking comments on a proposed rule that would prohibit transactions involving Vehicle Connectivity System (VCS)[1] hardware and covered software designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction of China (including Hong Kong) or Russia. Comments will be due
On July 10, BIS released new guidance strongly encouraging companies involved in exporting, reexporting, or transferring (in-country) Common High Priority List (CHPL) items to screen transaction parties against the list maintained by the Trade Integrity Project (TIP) (in addition to the Consolidated Screening List).
TIP is an initiative of the UK-based Open-Source Centre that
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:
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.
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