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

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 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

On August 28, 2020, China took its own swing in the fight over TikTok. The blow, however, may land right in the middle of U.S.-China technology research, collaboration, and innovation. New export regulations may require licenses from the Chinese government before researchers in China may share their technological advances with colleagues, counterparts, or customers in the United States.
Continue Reading China Expands Technology Export Controls: Fighting back on TikTok and Putting Your R&D at Risk

On Tuesday, May 19, the U.S. Commerce Department published a regulation (effective May 15, 2020) that prohibits sale to Huawei of a microchip made to a Huawei specification, made outside the United States with non-U.S. materials, sent from a foreign country, by a foreign person.

To quote the philosopher, hol’ up.

How is that even possible?
Continue Reading Huawei Whack-A-Mole: The U.S. Takes Another Swing at the Chinese Semiconductor Industry