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In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.

Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria
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The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.

Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III
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The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.

Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II
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The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.

Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I
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UPDATE: On February 5, 2025, the Trump administration issued an executive order delaying the cancellation of de minimis until “adequate systems are in place to fully and expediently process and collect tariff revenue applicable”. Imports from China below the value of $800 will generally not be subject to the 10% tariff or Section 301 duties.

Continue Reading The First Wave: U.S. Imposes Tariffs on Canada (or not?), Mexico (or not?), and China (well, yeah, probably so)
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In two recent rules, the Department of Commerce, Bureau of Industry and Security (BIS) has begun to take significant steps to monitor, and potentially control access to, U.S. artificial intelligence (AI) technology. AI continues to pose a unique challenge for regulators due to its rapid expansion as a consumer product and potential defense applications.

Continue Reading Commerce Takes on AI: Recent Developments from BIS on AI
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In a land before time (technologically speaking . . . so, like, the mid-nineties), the most basic software encryption functions were controlled under the U.S. International Traffic in Arms Regulations. The then-current version of Netscape or Lotus Notes (the hot tech of the era) were controlled under the same regulatory regime as missiles and fighter jets. Then, in 1996, an executive order moved encryption to commercial export controls and freed up the software industry to flourish into its current, omnipresent state.

Continue Reading The Commercial Industry Gets More Space: Reduced Export Controls Ease Cross-Border Collaborations (Part II of IV)
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On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten years. OFAC expects to publish an interim final rule to provide an opportunity to comment. The change will increase compliance obligations for entities engaged in transactions subject to U.S. sanctions.

Continue Reading SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement