BIS Releases FAQs on the Interim Advanced Computing Rule Regarding Advanced Computing and Semiconductor Manufacturing Items

On October 7, 2022, the United States Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Interim Advanced Computing Rule (“IACR”) targeting exports related to advanced computing integrated circuits and related commodities to the People’s Republic of China (“China”). The IACR also contains additional restrictions on semiconductor manufacturing and interactions with semiconductor manufacturing … Read more

U.S. Equipment Distributor Pays $140,000 on 14 Felony Counts of Failure to File Export Information

Last week, the United States Department of Justice (“DOJ”) announced the sentencing of Intertech Trading Corporation (“Intertech”) on fourteen felony counts under 13 U.S.C. § 305 for failure to file export information regarding shipments of “lab equipment” to both Russia and Ukraine. The DOJ initially brought these charges against Intertech in June 2022, and Intertech … Read more

DOJ Charges Russian and Venezuelan Nationals in Alleged Global Sanctions Evasion and Money Laundering Scheme

On October 19, 2022, the United States Department of Justice (“DOJ”) unsealed an indictment (the “Indictment”) charging five Russian nationals and two Venezuelan oil traders with various charges related to a complex scheme to evade U.S. sanctions directed at both Russia and Venezuela. Among other things, the Indictment alleges that Yury Orekhov (“Orekhov”), the CEO … Read more

BIS Implements Sweeping New Export Controls Targeting China

On October 7, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) took two significant actions with major implications for companies and persons dealing with the Chinese semiconductor and electronics sectors: BIS issued an interim final rule (the “IFR”) targeting exports to the People’s Republic of China that, among other things, imposes sweeping … Read more

OFAC, BIS Release New Russia Sanctions and Export Control Alert

Illustrating the trend of coordinated sanctions actions taken by the Treasury and Commerce Departments, last week the Office of Foreign Assets Control (“OFAC”) worked in tandem with the Commerce Department Bureau of Industry and Security to publish an Alert entitled, “OFAC-BIS Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex,” which discusses the … Read more

President Biden’s Executive Order Tightens CFIUS Scrutiny of Foreign Investments In Key US Sectors

As US toughens CFIUS oversight of foreign investments in sensitive sectors of the economy, we assess the key factors in play President Biden recently issued an Executive Order on Ensuring Robust Consideration of Evolving National Security Risks by the Committee on Foreign Investment in the United States (the Foreign Investment EO). It directs increased scrutiny by the Committee … Read more

U.S. Treasury Issues New Guidance on Russian Oil Price Cap

Our previous blog post discussed the G-7’s recent proposal to impose a price cap on Russian oil in an effort to diminish the energy revenues of the Russian state. In this post, we examine the new guidance issued by the U.S. Department of the Treasury (“Treasury”), Office of Foreign Assets Control (“OFAC”) establishing a framework … Read more

US Senate Calls for Designation of Russia as a “State Sponsor of Terrorism”

On July 27, 2022, the US Senate unanimously passed a nonbinding, bipartisan resolution to designate the Russian Federation as a “State Sponsor of Terrorism” (SST).  In parallel, a bipartisan group of members of the US House of Representatives introduced a bill on July 28, 2022 to designate Russia as an SST.  See H.R.8568.  These actions … Read more