On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The anti-circumvention rules are quite a novel aspect and could result in the first extraterritorial reach of European sanctions.
Continue Reading The EU’s 11th Sanctions Package: The Long(er) Arm of the Law
Recently, the Department of Commerce issued a memo, emphasizing that “technology protection is a core national security priority” and how companies that choose not to disclose significant violations of export regulations may have to bear concrete costs for non-disclosure. This memo highlights the continued focus to control U.S. technology security breaches, especially in the semiconductor and advanced computing industries.
It looks like the licensing restrictions on Huawei are trickling into effect.
Our sources indicate that, as early as February 27, all license applications for exports or transfers involving Huawei which were pending with the U.S. Bureau of Industry and Security (BIS) have been placed on Hold Without Action. Further, we understand from various industry sources that BIS has begun informing certain U.S. companies that they will not receive further licenses to export chips for end use by Huawei.
Continue Reading Breaking the Link – New Developments on U.S. Licenses for Exports to Huawei
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many industries.
Update and Correction: We had understood that the date for the announcement of a regulatory change would be February 13. That understanding is (pretty obviously, now, on February 14) incorrect. We still believe the change is imminent and will update as soon as we have further information.
Key takeaways
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.
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.
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