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Global Trade & Sanctions Law

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State Department Proposes Exempting Australia, UK from Certain Defense Related Export Controls

On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering activities between or among authorized users in the United States, United Kingdom (UK) and Australia. This announcement follows…

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Further Enhancing Australia, United Kingdom, United States (AUKUS) Trilateral Security Partnership through Export Controls

On April 19, 2024, the Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule reducing export control licensing requirements for Australia and the United Kingdom (UK) as a means to further strengthen the AUKUS trilateral security partnership between the three countries. With this rule, Australia…

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Treasury Announces Proposed Rule to Update CFIUS Regulations and Bolster Enforcement

On April 11, 2024, the U.S. Department of the Treasury (Treasury), as Chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM), which is the first substantive update to the mitigation and enforcement provisions of the CFIUS regulations since the Foreign…

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Correcting and Clarifying Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On March 29, 2024, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) issued an interim final rule (“2024 IFR”) clarifying and correcting its October 2023 interim final rules on advanced computing/supercomputers (AC/S IFR) and semiconductor manufacturing equipment (SME IFR) (collectively called the “2023 IFRs”). The 2023 IFRs further…

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U.S. Increases Export Restrictions against Nicaragua

The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the military end use and military end user restrictions. Additionally, the State Department’s Directorate…

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The BIS Issues an ANPRM to Address the National Security Risks from Connected Vehicles (CVs)

On March 1, 2024 the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public comment on regulations that aim to reduce the national security risks from connected vehicles (CVs) that incorporate technology from countries of concern, including the People’s Republic…

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With NATO Membership Official, Significant Business Opportunities Are Now Available to Swedish Companies

On March 7, 2024, Sweden officially joined the North Atlantic Treaty Organization (NATO) after Hungary’s parliament cleared the last hurdle to Sweden’s membership. Sweden and Finland began pursuing NATO membership following Russia’s invasion of Ukraine in 2022. Finland joined NATO in April 2023. Sweden’s accession, however, was met with significant…

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Key CHIPS Act Implementation Milestones and Opportunities for the Semiconductor Supply Chain

In 2023 and the early months of 2024, there has been a flurry of agency activity to implement key programs enacted under the CHIPS and Science Act—directing benefits to the semiconductor industry. In “Reviewing Key CHIPS Act Implementation Milestones to Deliver Opportunities for the Semiconductor Supply Chain,” Nancy A. Fischer, Aimee P.…

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China Year-in-Review: Supply Chains

This past year saw a continued trend in building supply chain resiliency, as this topic has grown increasingly important following COVID-19, the conflict in Ukraine, shifting landscape on tariffs, forced labor concerns and a number of other factors. Increasingly, supply chains are having to respond to policy concerns requiring shifting…

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BIS Issues Additional Enhancements to Voluntary Self-Disclosure Process

Takeaways On January 16, 2024, the Bureau of Industry and Security Office of Export Enforcement announced several updates to its VSD process aimed at enhancing the program’s overall efficiency and effectiveness. These enhancements create a more streamlined disclosure process for minor violations, including through abbreviated narratives, quarterly bundled disclosures, and…