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Julien Blanquart is an International Trade associate in the Governmental Practice in the firm's Brussels and London offices.

The Announcement

On Friday, October 7, 2022, the U.S. Bureau of Industry and Security (BIS) released for public inspection (available here) one hundred forty pages of regulations (which we’ll call “the Regulation” here). Nearly all of the changes in the Regulation restrict the export of semiconductors, as well as related technology, manufacturing equipment, software, and even U.S.-person support, to China.

Continue Reading China Semiconductor Export Regulations, Episode I – Counting Your Chips Carefully

** Update: Announcement has been moved to Friday October 7, 2022 at 9:30 AM Eastern Daylight Time **

On Thursday, the Biden administration will announce new restrictions preventing China from accessing advanced U.S. semiconductor technology.

Continue Reading Further Export Controls on Semiconductor Technology for China coming this Week

After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran over women’s rights and Iran’s authoritarian regime more generally. Iran’s police and other security forces are retaliating severely against protestors. In response to these human rights abuses, on September 22, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) sanctioned Iran’s morality police and senior leaders of Iran’s security organizations for the violence against protesters.

Continue Reading Technology to Iran: OFAC Lifts Certain Iran Sanctions In Response to Protests in Iran

The U.S. photovoltaic (PV) industry, solar module suppliers, manufacturers, and renewable energy developers are facing new regulatory challenges with the implementation of new legislation which has a significant impact on such imports. Among the most significant is the Uyghur Forced Labor Prevention Act, Pub. L. No. 117-78, 135 Stat. 1525 (2021) (“UFLPA”), whose provisions became fully effective on June 21, 2022.

Continue Reading Is the U.S. solar industry ready to prove its panels aren’t made with Uyghur forced labor?

On April 29, 2022, the UK introduced new measures to prevent the provision of internet services to or for the benefit of designated persons.[1] These measures apply to the whole territory of the UK and to conduct by UK persons where that conduct is wholly or partly outside the UK. The designated entities or individuals (“Designated Persons”) can be found on the regularly updated UK Sanctions List with the tag “Internet Sanctions List”. To date, only V-Novosti and Rossiya Segodnya are designated under those authorities.

Continue Reading Introduction of internet-related Russia trade sanctions in the UK

Updated as of April 12, 2022

It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed forces, the United States – in coordination with the G7 and the EU – imposed new sanctions on Russia (see here). The sweeping new sanctions seek to further restrict Russia’s access to dollars and put economic pressure on Putin to end the war. The sanctions include a ban on all new investment in Russia as well as designations of Russia’s largest financial institutions (i.e., Sberbank and Alfa Bank), critical state-owned enterprises, and Russian government officials and their family members, including Putin’s children.

Continue Reading U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine

Updated as of March 9, 2022

Key Takeaways of OFAC (Treasury), BIS (Commerce), and State Actions

  • Major Russian Banks Blocked from the U.S. Financial System


Continue Reading Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New U.S. Ukraine-Related Sanctions

Updated as of March 3, 2022

Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions

  • The EU adopted sanctions restrictions targeting financial institutions, other entities, and individuals, and imposing territorial restrictions on Donetsk and Luhansk. The sanctions also include broad export restrictions to Russia detailed below.
  • In the UK, Prime Minister Boris Johnson has promised and adopted a “massive package of economic sanctions” including asset freeze restrictions; potential exclusion of Russian banks from the UK financial system, including preventing access by such banks to GBP and clearing services in the UK; and dual-use export restrictions to Russia.


Continue Reading Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New EU and UK Ukraine-Related Sanctions

Updated as of February 25, 2022

Key Takeaways

  • On February 21, 2022, the White House issued a new Executive Order (EO) that imposes comprehensive sanctions


Continue Reading U.S., UK and EU Sanctions Over the Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) Regions of Ukraine

  • BIS added 33 Chinese companies to the Unverified List.
  • The UVL places lesser restrictions designees than an Entity List or Sanctions designation
  • BIS may not have been able to verify the entities because of new Chinese laws restricting compliance with extraterritorial laws; creating a potential conflict of laws for these and other companies.


Continue Reading Verify, Then Trust: Commerce Adds 33 Parties in China to Unverified List

Key Takeaways

  • The proposed regulation would arm the EU with a counterstrike capability if non-EU countries take economic action against a Member State.
  • Where a Member State is subject to economic interferences from non-EU states that affect its legitimate sovereign choices.
  • The European Commission to take some or all of the following measures against the interfering state:
    • Impose tariffs;
    • Implement quotas;
    • Restrict access to EU financial markets; or
    • Reduce intellectual property protections[1]


Continue Reading Arming for a Trade War: The EU Proposes an Unprecedented Anti-Coercion Regulation