The Department of Commerce’s Bureau of Industry and Security (BIS) has issued an Interim Final Rule amending General Prohibition Three, also known as the foreign-produced direct product reexport rule, so that this General Prohibition applies to certain additional foreign-made items destined for certain persons designated with a new footnote on BIS’ Entity List. Specifically, this

Due to continuing concerns with Huawei Technologies and its non-U.S. affiliates accessing and using U.S. technology and software to design and manufacture its semiconductors, the Department of Commerce (Commerce) announced that it will further tighten export restrictions on the Chinese conglomerate. Commerce’s  Bureau of Industry and Security (BIS) will amend its foreign-produced direct product rule

On May 14, 2020, the U.S. Departments of State and Treasury and the U.S. Coast Guard issued a global advisory to alert the maritime industry and those active in the energy and metals sectors to deceptive shipping practices used to evade U.S. economic sanctions.  It is intended to provide exporters, shippers and others utilizing the

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued two final rules and one proposed rule intended to prevent efforts by entities in China, Russia and Venezuela to acquire U.S. technology that could be used in development of weapons, military aircraft or surveillance technology through civilian supply chains or under civilian-use pretenses.

On April 23, 2020, the Department of State’s Directorate of Defense Trade Controls (DDTC) announced certain measures to mitigate the impact of the pandemic on U.S. companies and supply chains overseas. Key measures from the announcement are summarized below.


  • Effective for registrations originally expiring between February 29 and June 30, 2020, registrations as a

On April 7, 2020, the U.S. Department of Homeland Security’s Federal Emergency Management Agency (FEMA) issued a temporary final rule (“Rule”) to establish export restrictions on certain types of personal protective equipment (PPE) products and respirators (“Covered Products”) used in the response to the COVID-19 pandemic. The Rule implements the presidential memorandum dated April 3,

On April 17, 2020, the Federal Emergency Management Agency’s (FEMA) filed a notification of exemptions (the “Exemptions”) that identifies 10 exemptions from the temporary final rule published on April 10, 2020 (the “Rule”), which restricts the export from the United States of certain personal protective equipment (PPE) and respirators in the response to the COVID-19

On April 16, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a fact sheet noting that the sanctions programs it administers generally allow for legitimate humanitarian-related trade, assistance or activity under existing laws and regulations. The fact sheet provides consolidated guidance highlighting the most relevant exemptions, exceptions and authorizations for

Please join us for a webinar on Thursday, April 30 from noon to 1:15 p.m. ET discussing the impact of the COVID-19 pandemic on international trade. During the webinar we will discuss:

  • U.S. and foreign government restrictions on the export of personal protective equipment (PPE)
  • Impact on U.S. customs duties
    • Section 301 tariff product exclusions