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.…
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…
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…
During 2023 both Congress and the Biden Administration repeatedly expressed the need to secure critical supply chains, particularly batteries that rely heavily on lithium and critical minerals sourced from China. Concerns have been framed in terms of national security focusing on the danger of relying too heavily on products integral…
On January 17, 2024, the U.S. Department of State announced the redesignation of the Yemen-based Ansarallah (commonly referred to as the “Houthis”) as a Specially Designated Global Terrorist organization (SDGT). The decision to redesignate Ansarallah comes after several months of attacks by Houthi forces against international maritime vessels in both…
In 2023, the United States sharpened its focus on deterring China’s ability to develop advanced technology with the potential to threaten U.S. national security. To do so, the U.S. government has implemented several new restrictions and requirements related to critical technologies. Some of these measures, such as the announcement of…
2023 witnessed significant developments from the United States government aimed at countering China’s influence and curbing potential threats to U.S. national security. These developments have spanned legislative and administrative action, shifting long-standing paradigms within export controls, import controls, and sanctions. The Biden Administration is increasingly utilizing these tools as strategic…
The United Kingdom introduced new sanctions against Russia on December 14, 2023, with the European Union also adopting its twelfth package of sanctions against Russia on December 18, 2023. The latest UK restrictions include: Import and related restrictions on further categories of iron and steel goods, as well a wide range…
On October 5, 2023, the National Archives Information Security Oversight Office (ISOO) released a joint notice to provide guidance on facility clearances for joint ventures (JVs) in the National Industrial Security Program (NISP). This guidance addresses the interaction of NISP requirements and an October 16, 2020 Small Business Administration (SBA)…
On November 6, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced a $206,213 settlement with Swift Prepaid Solutions, Inc. d/b/a daVinci Payments (daVinci) for apparent violations of sanctions regarding Crimea, Iran, Syria and Cuba. The financial services and payments firm was penalized by OFAC for…