Top Story

DPRK Telework Scheme Targeted

Mansudae Monument, Pyongyang
The Justice Department announced a series of coordinated actions to disrupt the illicit revenue generation efforts North Korean information Technology workers, while the State Department announced a $5 million reward to help shut down the schemes.
Sultanahmet Mosque (Blue Mosque) - Istanbul, Turkey
BIS Antiboycott Advisory on Türkiye
In response to Ankara's suspension of trade with Israel,The US Department of Commerce's Bureau of Industry and Security (BIS) has issued an antiboycott advisory on Turkey. U.S. companies operating in Türkiye, in particular, are cautioned to be alert to their receipt of any requests to refrain from importing or exporting goods to or from Israel or to provide certification that the goods are not of Israeli origin or do not contain Israeli-origin components or materials. 
DHS Lists More Chinese Cotton Traders
The Department of Homeland Security (DHS) announced the addition of 26 textile companies based in the People’s Republic of China (PRC) to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.
Solar Imports Tightened
May 16, the Administration announced new actions to protect American solar manufacturing from Chinese competition, including removing the bifacial module exclusion under Section 201, announcing the end of the 24 month "bridge," permitting duty free imports from ASEAN suppliers, and enhanced monitoring of trade flows.

Welcome to your new Export Practitioner

The Export Practitioner introduces a web-based format for easier review, research and sharing.  

In addition to your monthly print or e-edition, we can furnish mid-month updates for our readers. 

We seek your input as we make this transition. Please send your suggestions to fruffing@traderegs.com or call 703.283.5220.   

– Frank Ruffing, Editor 

Our latest news

Dems Criticize DoC on Firearms

Sen. Elizabeth Warren (D-Mass) and three House Democrats criticized the Commerce Department for what they say are inadequate steps to address assault weapons exports. At the same time, the lawmakers praised the US Trade Representative’s Office for no longer classifying as trade barriers import license requirements for explosives, firearms and ammunition in its latest National Trade Estimate report.

Concern China Could Evade EV Tariff

The Administration is very concerned that China may try to evade the new 100 percent tariffs on Chinese electric vehicles, Commerce Secretary Gina Raimondo told lawmakers Wednesday. The US Trade Representative’s Office, with assistance from the Commerce Department, is looking at how to ensure Chinese EVs made in Mexico are still subject to the tariff, she told members of the Senate Appropriations commerce, justice, science and related agencies subcommittee.

HFAC Markups Thursday 16 May

The House Foreign Affairs Committee held a markup to consider various measures on Thursday, May 16th.

OFAC Backlog Reported Growing

The termination of general license 44A, which had offered temporary relief from Venezuel oil sanctions, reportedly has created a crush of license applications to OFAC.

AML/CFT Treasury Strategy Released

The Treasury Department issued the 2024 National Strategy for Combatting Terrorist and Other Illicit Financing , which provides a blueprint of the U.S. government’s goals, objectives, and …

More Sudan Rebel Leaders Sanctioned

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Ali Yagoub Gibril and Osman Mohamed Hamid Mohamed, pursuant to Executive Order (E.O.) 14098, for leading the Rapid Support Forces’ (RSF) war campaign. The RSF’s attacks in North Darfur, which started last month, have caused dozens of civilian casualties, including children.
Enforcement
The Disruptive Technology Strike Force meets with US government and private sector partners to discuss the threat to advanced U.S. technology from hostile foreign governments and its efforts to …
A Florida woman pleaded guilty to 25 felony counts in Florida federal court, related to a scheme to falsely represent parts manufactured by a debarred Turkish fabricator were of American Origin. Among violations were the export of sensitive military drawings and specifications, despite the clear warnings on the face of each drawing that it could not be exported without obtaining a license.
U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Advisory to assist financial institutions in detecting potentially illicit transactions related to …
Sanctions

More Sanctions for DPRK - Russia Arms Traders

Treasury’s Office of Foreign Assets Control (OFAC) is imposing sanctions on two Russian individuals and three Russia-based entities for facilitating weapons transfers between Russia and the Democratic People’s Republic of Korea (DPRK).

US Sanctions Nicaraguan Gold Miners and Russian Training Center

Treasury is imposing sanctions on three Nicaragua-based entities, the Training Center of the Russian Ministry of Internal Affairs in Managua (RTC); Compania Minera Internacional, S.A. (COMINTSA); and Capital Mining Investment Nicaragua, S.A. The RTC is a Nicaragua-based subdivision of the Government of the Russian Federation’s (GOR) Ministry of Internal Affairs, and is a "key actor in the Nicaraguan regime’s repression of civil society and unjust detention and imprisonment of individuals for expressing dissent, or otherwise peacefully exercising their human rights and fundamental freedoms," according to the OFAC statement. The designations of COMINTSA and Capital Mining target government-affiliated gold companies generating revenue for the Ortega-Murillo regime. Gold is Nicaragua’s top commodity export.

Treasury Stops Austrian Deal with Oligarch, Sanctions Parties

Treasury’s Office of Foreign Assets Control (OFAC) designated one Russian individual and three Russia-based companies involved in an attempted sanctions evasion scheme in which an "opaque and complex supposed divestment" could have unfrozen more than $1.5 billion worth of shares belonging to U.S.-designated Russian oligarch Oleg Deripaska. The transactions was part of a scheme to repatriate some of Austria's  Raiffeisen Bank capital stranded in Russia.
Policy Briefs
A bill has been introduced in Congress to close a loophole in U.S. export control laws that is being exploited by China, according to its sponsors.   The Remote Access Security Act will ensure …
House China Hawks introduced the “Enhancing National Frameworks for Overseas Critical Exports Act” (ENFORCE Act), modifying the Export Control Reform Act of 2018 (ECRA) The ENFORCE Act amends ECRA to give BIS the authority to export control-covered AI systems.
A bipartisian group of lawmakers has introduced  BIOSECURE Act, a bill to ensure American patient data and taxpayer dollars do not fall into the hands of foreign adversaries' biotechnology companies of concern by prohibiting Federal contracting with these companies. The Chinese Communist Party's (CCP) national security laws require all Chinese firms to share any requested data with the CCP, including biotechnology companies that collect, test, and store American genomic data.
Supply Chain
Drones for First Responders (DFR) Act will  implement a new tariff on Communist Chinese-controlled drones and use the tariff revenue to establish a new grant program to help first responders, critical infrastructure providers, and farmers, purchase secure drones.
The President signed H.R. 1042, the Prohibiting Russian Uranium Imports Act, into law May 13, 2024.   This bipartisan legislative action prohibits the import of Russian uranium products into the United States as of August 12, 2024, while enabling a three and a half year waiver process through January 1, 2028.
Ambassador Katherine Tai issued a statement Monday regarding the   finding against the United States in a determination regarding a labor dispute at the San Martin lead, zinc, copper and silver mine in the Mexican state of Zacatecas: The Rapid Response Labor Mechanism (RRM) panel established under the United States-Mexico-Canada Agreement (USMCA) determined that the agreement had no jurisdiction in the decades long labor dispute.
Licensing
Since Russia’s full-scale invasion of Ukraine in February 2022, Chinese exports to Russia have risen by more than 60 percent .  Nathaniel Sher writes in Canegie Politika (link) that this trade is "nothing short of a lifeline to Russia's economy."
Directorate of Defense Trade Controls, Bureau of Political Military Affairs, Department of State (T/PM/DDTC) is surveying Individuals and companies registered with DDTC and engaged in the business of manufacturing, brokering, exporting, or temporarily importing defense hardware or defense technology data.   The information collection in question is the Statement of Material Change, Merger, Acquisition, or Divestiture of a Registered Party.
A bipartisan group of senators have introduced legislation aimed at expanding the Australia- United Kingdom-United States partnership to include Japan in order to combat the growing threat of China. The Coordinating AUKUS Engagement with Japan Act directs the two AUKUS coordinators at the U.S. Departments of State and Defense to engage with Japan, and consult with counterparts in the U.K. and Australia, at technical level to better understand how Japan could augment the partnership and what steps Japan might need to take in order to engage quickly and meaningfully in AUKUS advanced technology projects.
BIS Publishes final rule making conforming and clarifying changes to the Export Administration Regulations (EAR). These changes include making conforming changes to the EAR to ensure that destination names reflect the current destination names that are recognized by the United States Government, clarifying the removal of certain license requirements for exports, reexports, and transfers (in-country) to and within Australia and the United Kingdom, making a conforming change to reflect that Cyprus is no longer a Country Group D:5 country, and clarifying how Russia and the Russian Federation are referenced for consistency with the designation of Russia as a U.S. Arms Embargoed destinations.
Reuters reports the Commerce Department is considering a new regulatory push to restrict the export of proprietary or closed source AI models There are currently no restrictions on the sale of AI models to foreign adversaries, presenting a potential national security risk.