The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick.Continue Reading E(U)xterritoriality of EU Sanctions: The No Russia Clause
Protective Packaging: The EU’s Economic Security Package Changes the Landscape in Global Technology Controls
The EU plans to step up controls on its home-grown technology. That is the short version.Continue Reading Protective Packaging: The EU’s Economic Security Package Changes the Landscape in Global Technology Controls
China Semiconductor Export Regulations, Episode III – What a Difference a Year Makes
Key Takeaways
- Advanced Computing and Supercomputing ECCNs are expanded.
- Controls applied to exports to countries other thanChina; countries from where items may be reexported to China.
- Chipmaking equipment controls are expanded and the de minimis rule reduced.
- New entities are added to the U.S. Entity List with the Footnote 4 (FN4) FDPR designation.
- More U.S.-person activity is controlled.
The EU’s 11th Sanctions Package: The Long(er) Arm of the Law
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
Technology Protection is a Core National Security Priority: BIS Strengthens Its Policy on Disclosures
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.Continue Reading Technology Protection is a Core National Security Priority: BIS Strengthens Its Policy on Disclosures
Breaking the Link – New Developments on U.S. Licenses for Exports to Huawei
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
Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of Iranian UAVs)
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.Continue Reading Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of Iranian UAVs)
Tightening the Cordon – U.S. Restricts Licensing Policy and Adds Allies to Technology Controls
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
- Soon, the U.S. government will officially issue a stricter policy of denial for providing lower-tech items to Huawei.
- Technological containment continues as the Netherlands and Japan move to impose U.S.-style restrictions on semiconductor exports to China.
China Semiconductor Export Regulations, Episode I – Counting Your Chips Carefully
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
Further Export Controls on Semiconductor Technology for China coming this Week
** 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
Technology to Iran: OFAC Lifts Certain Iran Sanctions In Response to Protests in Iran
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