As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide. That guide, which was last updated in March 2024, includes numerous case examples illustrating BIS’s criminal and administrative enforcement actions. The update also comes with two additional BIS publications addressing measures to reduce diversion risks and a six-year review of BIS’s licensing strategy.Continue Reading BIS Summer Update: Essential Reading for Your Next Beach Trip!
license
Hotels and Hospitality in Cuba: OFAC and Obama Paving the Way
With more flights, relaxing regulations, a historic presidential trip to Cuba, and news of hospitality services expanding into Cuba, the pathway into Cuba for hotels and hospitality companies seems smooth. But businesses should look out for the potential hurdles and compliance risks. Don’t fret – we can help you welcome your guests.
Continue Reading Hotels and Hospitality in Cuba: OFAC and Obama Paving the Way
Starving the Bear: The United States Restricts Exports to Russia
The pressure on Russia continues to build. As we previously reported here and here, throughout March, the United States and other Western powers implemented a series of sanctions against individuals and entities deemed to be involved in the political destabilization of Ukraine. Those sanctions were restricted to specific parties, including high ranking Russian and Ukrainian officials and – notably – one Russian bank.
Continue Reading Starving the Bear: The United States Restricts Exports to Russia
Export Control Reform Series Episode III: Harmonizing EAR Exceptions and ITAR Exemptions
By: Fatima Merchant
Background
In Episode 1 and Episode 2 of this series, we discussed some key points of U.S. Export Control Reform and took you through a step-by-step reclassification analysis of parts and components transitioning from the USML to the EAR. After determining that the items you export will move from the USML to the CCL, you will need to evaluate your licensing requirements.
Continue Reading Export Control Reform Series Episode III: Harmonizing EAR Exceptions and ITAR Exemptions