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FDP Rule Scope Expanded for Iran, Russia, Belarus

Effective April 18th, a new rule from BIS amends the EAR to impose new controls restricting Iran’s access to additional low-level technology, including items manufactured outside the United States that are produced using U.S. technology. The rule also expands the scope of the Russia/Belarus/Temporarily occupied Crimea region of Ukraine Foreign Direct Product (FDP) rule and the Iran FDP rule: the items in supplement no. 7 to part 746 will now include the entirety of the ‘Common High Priority List’ (CHPL).
Senator Maggie Hassan Chairing Hearing Thursday
Senate Focus on Export Control Enforcement
Wednesday Senators Mitt Romney (R-UT) and Maggie Hassan (D-NH), introduced bipartisan legislation to bolster the Export Enforcement Coordination Center—an interagency hub for information sharing and coordination among the key agencies responsible for export control enforcement. At a hearing Thursday, officials from Commerce, Justice and Homeland Security were unanimous in their call for resources from Congress.
Thea Kendler talks with reporters at the BIS Update Conference
BIS Export Administration: New Organization
Export Administration is getting a new leadership framework, including the creation of Deputy Assistant Secretary roles for Strategic Trade and Technology Security, under the oversight of the newly elevated Principal Deputy Assistant Secretary Matt Borman. The Changes involve dividing EA’s functions into two primary channels: Strategic Trade, focusing on licensing, outreach, and training, and Technology Security, which encompasses defense industrial base (DIB) responsibilities, analysis, and regulatory work.
Assistant Secretary for Export Enforcement Matthew Axelrod (r) and Under Secretary of Commerce for Industry and Security Alan Estevez (l) at the BIS Update Conference
BIS Enforcement: Four New Initiatives
Assistant Secretary for Export Enforcement Matthew Axelrod announced four new Enforcement Initiatives at the 2024 Update Conference on Export Controls and Policy. In his plenary address, Mr. Axelrod introduced new guidance for the Freight Forwarder community, an updated compendium of enforcement examples, an antiboycott blacklist, and enhanced outreach to manufacturers and distributors of restricted good discovered on the battlefield in Ukraine.

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Our latest news

EU, UK Urged to Ban Forced Labor Imports

The leaders of the House Select Committee on China are calling on the Administration to press allies – particularly Europe and the United Kingdom – to prevent Chinese goods made by Uyghur forced labor from entering their markets. “We are particularly concerned that goods made by Uyghur forced labor continue to flood into Europe and the United Kingdom (UK), which some have described as ‘dumping grounds’ for these products that are otherwise banned from importation into the United States,” Committee Chairman Mike Gallagher (R-Wis) and ranking Democrat Raja Krishnamoorthi (Ill) wrote in a letter to Secretary of State Antony Blinken.

ExIm Approves Domestic Project

The US Export-Import Bank Board of Directors has approved a $51 million direct loan to small business Packwell, Incorporated to support the construction of a packaging and warehousing facility in Houston. This transaction, approved yesterday, is the third under the Make More in America initiative. The transaction is estimated to support approximately 320 jobs in Houston.

China Committee Chairs Slam Funding of Blacklisted Firms

A new report from the House Select Committee on China found that US financial institutions have facilitated investment of more than $6.5 billion to 63 Chinese companies that the US government has red-flagged or blacklisted for advancing Beijing’s military capabilities or supporting its human rights abuses.

Justice Roundup: DPRK in Thailand; Iraq - Sudan Arms Trade;

Arms dealers to Sudan & Iraq; Pennsylvanian sentenced for torture & arms to Iraq; DPRK diplomat money laundering

D.O.C. Export Week May 6-10

Export Week May 6-10 will offer 50 virtual or in-person tradecraft & industry-focused seminars. Sign up for one or more of these sessions. Specially designed for exporters of all experience …

Thai Plastics Firm Fined $20 Million for Iran Sanctions

Treasury's Office of Foreign Assets Control (OFAC) announced a settlement with SCG Plastics Co., Ltd., part of a multinational enterprise headquartered in Bangkok, Thailand. SCG Plastics has agreed to pay $20,000,000 to settle its potential civil liability for 467 apparent violations of OFAC sanctions on Iran.
The president of Orlando, Florida-based steel trading firm Metalhouse LLC, was sentenced to six years in prison for conspiracy to commit money laundering to promote violations of U.S. sanctions against Sergey Kurchenko, a pro-Russian Ukrainian oligarch.   A business associate, a Belarusian national residing in Miami, was sentenced to 21 months in prison for his role in the scheme.
Public Company Accounting Oversight Board (PCAOB) Chair Erica Y. Williams announced a record $25 million fine sanctioning KPMG Netherlands for widespread improper answer sharing and the firm's multiple misrepresentations about its knowledge of the misconduct.
Two Russian nationals pleaded guilty last week to conspiracy to violate the Export Control Reform Act (ECRA) in connection with a scheme to acquire and unlawfully export controlled aviation technology to Russian end users. Beginning in or about May 2022 through May 2023, the defendants conspired to obtain orders for various aircraft parts and components from Russian buyers – primarily commercial airline companies – and then fulfill those requests by acquiring the parts from the United States suppliers.
Bahman Trail 230 Motorcycle

More Iran Firms Sanctioned

Treasury’s Office of Foreign Assets Control (OFAC) is taking sweeping actions against several actors involved in Iran’s unmanned aerial vehicle (UAV) program, suppliers and customers of one of Iran’s largest steel producers, and Iranian automobile companies with connections to U.S.-designated entities Islamic Revolutionary Guard Corps (IRGC) and the Ministry of Defense and Armed Forces Logistics (MODAFL).

Ballistic Missile Suppliers Sanctioned

The State Departemnt designated four entities pursuant to Executive Order 13382, which targets proliferators of weapons of mass destruction and their means of delivery. These entities – three based in the People’s Republic of China and one in Belarus – have supplied missile‐applicable items to Pakistan’s ballistic missile programs, including its long-range missile program.

Belarus Sanctions Broadened

In an effort to further isolate the Russian and Belarus military-industrial complex,  the U.S. Treasury’s Office of Foreign Assets Control (OFAC) is designating 12 entities and 10 individuals pursuant to Executive Order (E.O.) 14038,  The individuals and entities OFAC is targeting include six revenue-generating state-owned enterprises (SOEs) and one entity and five individuals involved in facilitating transactions for a U.S.-designated major Belarusian defense sector enterprise.
Policy Briefs
The USTR has requested a Rapid Response Labor Mechanism (RRM) panel under the United States-Mexico-Canada Agreement (USMCA) to resolve a labor dispute at call center operator Atento Servicios, S.A. de C.V. .    At the conclusion of its 45-day review period, Mexico found a denial of rights had existed, but determined that Atento Servicios had taken the necessary actions to remediate the denial of rights during Mexico’s review period. The United States disagrees with this determination and is requesting establishment of an RRM panel to review the situation.
Airline industry and labor groups are calling for restrictions on Chinese Airline flights to the US, citing unfair competition. The groups have asked for a "pause" to additional passenger flights between the United States and China "until U.S. workers and businesses are guaranteed equality of access in the marketplace, free from the existing harmful anti-competitive policies of the Chinese government. "
The U.S. and UK Monday signed a Memorandum of Understanding (MOU) which will see them work together to develop tests for the most advanced AI models, following through on commitments made at the AI Safety Summit last November.   Signed by U.S. Commerce Secretary Gina Raimondo and UK Technology Secretary Michelle Donelan, the partnership will see both countries working to align their scientific approaches and working closely to accelerate and rapidly iterate robust suites of evaluations for AI models, systems, and agents.
Supply Chain
U.S. Department of Commerce and TSMC Arizona  a subsidiary of Taiwan Semiconductor Manufacturing Company Limited (TSMC), have signed a non-binding preliminary memorandum of terms (PMT) to provide up to $6.6 billion in direct funding under the CHIPS and Science Act.
U.S. Customs and Border Protection (CBP) personnel at all U.S. ports of entry will detain work gloves manufactured by Shanghai Select Safety Products Company, Limited and its two subsidiaries.. CBP issued a Withhold Release Order (WRO) against Shanghai Select Safety Products Company, Limited and its two subsidiaries Nantong and HK, based on information that reasonably indicates the use of convict labor in violation of 19 U.S.C. § 1307 in the production of that merchandise.
The United States announced two resolutions of labor disputes initiated under the USMCA facility-specific Rapid Response Labor Mechanism (RRM) in Mexico last year.   The Turkish owners of the Teklas Automotive hose assembly plant and the Mexican owners of the Draxton automotive casting operations, both in central Mexico,   conducted remediation satisfactory to US officials. USTR has directed the Secretary of the Treasury to resume liquidation of unliquidated entries of goods from the facilities.
The Commerce Department's Bureau of Industry and Security (BIS) published an interim final rule significantly reducing licensing requirements for Australia and the United Kingdom (UK) to foster defense trade and technological innovation. BIS is removing Commerce Control List (CCL) license requirements to allow Commerce-controlled military items, missile technology-related items, and hot section engine-related items to be exported or reexported to Australia and the UK without a license.  Similar relaxation by the State Department on ITAR controlled technology can be expected "over the course of the next 120 days," according to a statement.
The Bureau of Industry and Security (BIS), Department of Commerce is announcing its recruitment of candidates to serve on one of its six Technical Advisory Committees (“TACs”). TAC …
The United States will publish a list of advanced Chinese chipmaking factories barred from receiving key tools, Reuters reported Thursday, citing three separate sources. The list could be released in the next couple of months, according to the report..
BIS has published corrections and amendments to the October 25 2023 Semicinductor and Advanced Computing Rules. This rule corrects inadvertent errors in those rules and makes additional clarifications for the two rules. China has expressed strong opposition to the latest U.S. revised rules on semiconductor export rules, saying that it will disrupt the global semiconductor market as well as cooperation between enterprises.
The Commerce Department's Bureau of Industry and Security 2024 Update Conference kicked off Wednesday to a full house in Washington, with over 1,100 attendees registered and many breakout sessions extended to overflow rooms with video feeds. While Commerce Secretary Gina Raimonda was unable to attend in person, Under Secretary of Commerce for Industry and Security Alan Estevez greeted attendees with a recap of the work undertaken since the last conference in 2022, and insights on where things are headed.