Cover story

Congress Bulls in China Shop

February month saw the 118th Congress find their new offices, stand up their new committees, and raise a chorus from both sides of the aisle for more participation in trade policy.  
Around the regions
United States

White House Amps Up Pressure on Russia

The White House marked the anniversary of Russia’s invasion of Ukraine with a raft of spending, tariffs, sanctions and export controls aimed at Russia and her enablers. 

Justice and BIS / Export Enforcement Task Force

The National Security Division of Justice and the Commerce’s Bureau of Industry and Security (BIS) are joining with the FBI, Homeland Security Investigations (HSI) and 14 U.S. Attorneys’ …

China Blacklists US Defense Contractors

China touted its own sanctions blacklist, placing Lockheed Martin and Raytheon Missiles & Defence to China’s “Unreliable Entity List” over their participation in arms sales to …

BIS: Chips Rules Add Macau

This rule adds the destination of Macau to the scope of the Regional Stability (RS) controls that were implemented specific to China in the October 7 advanced computing and semiconductor manufacturing equipment rule. …
Elizabeth Rosenberg, the assistant Treasury secretary for terrorist financing and financial crimes, added to the drumbeat of criticism of sanction dodging regimes, telling a meeting of Women in International Trade that the UAE was a “country of focus” for the US.
Justice announced the arrest of the principals of a Kansas avionics distributor for  the export of  aviation technology from the United States to Russia and Russian end users.
Ilya Balakaev, 47, of Moscow, was charged In the Eastern District of New York with various offenses related to a years-long scheme to illegally smuggle sensitive devices used in counterintelligence operations from the United States to Russia for the benefit of the Federal Security Service of the Russian Federation (FSB), the principal intelligence and security agency of the Russian government.
European Union
The European Commission has released a proposal to harmonize criminal offences and penalties for the violation of EU restrictive measures. Individual persons could be liable to a maximum penalty of …
The European Commission is proposing to create a new structure to manage frozen and immobilized public Russian assets, invest them and use the proceeds for Ukraine. The announcement includes measures …
United Kingdom
Solicitors Regulation Authority has published guidance on the UK Sanctions Regime for SRA-regulated firms, solicitors, registered European lawyers and registered foreign lawyers. “The sanctions …
UK’s Second Economic Crime Bill is at odds with the EU decision. Hogan Lovells reminds clients, “An existing overseas entity (and its officers) who owns land but has failed to register at …

Wells Fargo Fined for Lax Sanctions Compliance

The Treasury and Federal Reserve have jointly fined Wells Fargo Bank nearly $100 million for failing to prohibit sanctions violations conducted on its trade finance platform Eximbills over a period of seven years.

FCPA / Justice Buries the Hatchet with Ericsson

Swedish Telecoms giant and serial FCPA violator LM Ericsson signed a new deal with the Justice Department acknowleging further breaches of the deferred prosecution agreement it entered into for corruption in Djibouti, China, Vietnam, Indonesia and Kuwait.    

Blueprint and Alloy Exports Yield BIS/DDTC Settlements

Additive manufacturer 3D Systems agreed  to pay $12,777,750, engage a consultant and complete compliance audits to settle allegations of violations of Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR) by exporting controlled aerospace technology and metal alloy powder to China without the required license, ...

BIS Blacklist Growth Continues

The Bureau of Industry and Security added 37 entities under 38 entries to the Entity List March 2nd, including 28 Chinese firms.

Joint Compliance Note on Third Party Actors

Signaling a redoubled focus on countries providing conduits to evade western sanctions, Commerce’s Bureau of Industry and Security, the Department of Justice and Treasury’s Office of Foreign Assets Control, issued a Tri-Seal Compliance Note to …

OFAC: Venezuela GL Updates

Treasury's Office of Foreign Assets Control (OFAC) is publishing two general licenses (GLs) issued pursuant to the Venezuela Sanctions Regulations, each of which was previously made available on …
Policy Briefs

Anti-Money Laundering Group Suspends Russia, Publishes AML Standards, Guidance

The Financial Action Task Force (FATF), an intergovernmental body that establishes international standards for anti-money laundering, suspended Russia from its ranks, citing the Russian Federation’s "actions unacceptably run counter to the FATF core principles aiming to promote security, safety, and the integrity of the global financial system.” The FATF also issued long-awaited guidance for members to implement its Recommendation 24, requiring countries to ensure that competent authorities have access to adequate, accurate and up-to-date information on the true owners of companies.

McCaul Leans In on BIS Coddling Chinese

House Foreign Affairs Committee Chairman Michael McCaul released his interpretation of data on licensing outcomes from the Department of Commerce’s Bureau of Industry and Security (BIS) …

FISA / Section 702 Re Approval Campaign Kickoff

Marking the kickoff of a campaign to build support for the extension of Section 702 of the Foreign Intelligence Surveillance Act (FISA), Assistant Attorney General Matthew Olsen defended the measure in a speech at the Brookings Institution February 28th.

BIS: Section 1758 Bio & Toxins Rule Set

The Bureau of Industry and Security (BIS) published the final rule to amend the Export Administration Regulations (EAR) to reflect decisions made at Australia Group (AG) Virtual Implementation …

DDTC: Voluntary Disclosure – Violations of the Arms Export Control Act 

ITAR §127.12 describes the information which should accompany a voluntary disclosure. Historically, respondents to this information collection submitted their disclosures to DDTC in writing via …

State/DDTC: Seeks Comments on Open GL Recordkeeping 

 DDTC has launched a pilot program pursuant to its authorities in ITAR § 120.22(b) in order to assess the concept of an Open General License (OGL) mechanism by which it may authorize …