Archives: Export Controls

Subscribe to Export Controls RSS Feed

Unmanned Systems and Export Controls: What Your Company Needs to Know

Steptoe’s Anthony Rapa authored a piece titled “Unmanned Systems and Export Controls: What Your Company Needs to Know” for the May 2018 edition of Unmanned Systems magazine. The article gives an overview of US commercial and military export controls, discusses the application of export controls to unmanned systems, and offers tips for complying with these … Continue Reading

Upcoming Webinar: Export Controls for Encryption Items

On Thursday, April 26 at 11:00 AM EST, Anthony Rapa will present “U.S. Encryption Export Controls”, a webinar hosted by Federal Publications.  As described on the Federal Publications website: Our export controls trilogy reaches a riveting conclusion with a discussion of U.S. encryption controls. This webinar will explore encryption controls in place under the U.S. Export Administration … Continue Reading

ZTE Denial Order Imposed

On April 16, 2018, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) imposed a denial order involving Zhongxing Telecommunications Equipment Corporation of Shenzhen, China (ZTE Corporation) and ZTE Kangxun Telecommunications Ltd of Hi-New Shenzhen, China (ZTE Kangxun).  The denial order, effective immediately, restricts ZTE Corporation and ZTE Kangxun from participating in any … Continue Reading

Webinar on Application of U.S. Export Controls Outside the United States

On Thursday, March 29 at 11:00 AM EST, Anthony Rapa will present “Dual-Use Export Controls: Application of U.S. Export Controls Outside the U.S.”, a webinar hosted by Federal Publications.  As described on the Federal Publications website: When do U.S. dual-use export controls apply outside the United States? Much more often than you might think.  This … Continue Reading

Dual-Use Export Controls Webinar

On Tuesday, February 27 at 11:00 AM EST, Anthony Rapa will be presenting “Introduction to Dual-Use Export Controls: U.S. EAR and EU Dual-Use Regulation”, a webinar hosted by Federal Publications.  As described on the Federal Publications website: Are you involved in the flow of goods, software, or technical data across borders?  If so, you might … Continue Reading

WorldECR Publishes Article on EAR License Exceptions

Steptoe’s Ed Krauland and Anthony Rapa authored an article on Export Administration Regulations (EAR) license exceptions published in WorldECR’s July 2017 issue. The article discusses the pros and cons of license exceptions, which can offer exporters a host of cost, time, and efficiency benefits. They argue that, when mastered, these license exceptions can be a … Continue Reading

BIS Amends EAR Based on Missile Technology Control Regime Plenary Agreements

On July 7, 2017, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule amending the Export Administration Regulations (“EAR”) based on the 2016 Missile Technology Control Regime (“MTCR”) plenary agreements. The MTCR is a multilateral export control regime designed to control the export of certain goods and technology that … Continue Reading

BIS Updates Encryption Export Controls Guidance

The Bureau of Industry and Security at the US Department of Commerce has updated the information on its website to incorporate changes made to its encryption export rules in September of 2016.  The new information includes a helpful reference guide for Category 5, Part 2 of the Export Administration Regulations, flowcharts, and guidance on license … Continue Reading

ZTE Settlement Marked by Record Penalty and Lessons Learned

China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Limited, and their subsidiaries and affiliates, (collectively, ZTE), reached a historic combined $1.19 billion settlement with the US government on March 7, 2017.  This settlement resolves export controls and sanctions violations associated with shipments of US-origin equipment to Iran and North Korea.  ZTE pled guilty to … Continue Reading

ZTE Enters Multi-Agency Settlement to Resolve Sanctions and Export Controls Allegations

On March 8, 2016, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added major Chinese telecommunications company Zhongxing Telecommunications Equipment (“ZTE”) and three ZTE affiliates to the BIS Entity List, alleging that the ZTE entities developed a scheme to re-export controlled items to Iran in violation of US export controls and sanctions … Continue Reading

BIS Again Extends ZTE Temporary General License

On February 24, 2017, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) is publishing in the Federal Register a notice again extending its temporary general license for exports, reexports, and in country transfers to Zhongxing Telecommunications Equipment (ZTE) Corporation (ZTE Corporation) and ZTE Kangxun.  BIS is extending the period of the license … Continue Reading

Commerce Department Eases Certain Export Controls on India

Tomorrow, the Commerce Department’s Bureau of Industry and Security (BIS) will ease certain U.S. export controls on India, as part of the U.S. commitments under the India–U.S. Joint Statement of June 7, 2016, which recognized the United States and India as Major Defense Partners.  BIS is amending the Export Administration Regulations (EAR) to establish a … Continue Reading

New DOJ Guidance Could be a Game Changer for Export Controls and Sanctions Enforcement

Steptoe’s Meredith Rathbone and Peter Jeydel co-authored an article in Risk & Compliance, “New DOJ Guidance Could be a Game Changer for Export Controls and Sanctions Enforcement.”  The article was published in the January-March issue and centers on how the US Department of Justice’s guidance may cause difficulties and new risks for industries. For more … Continue Reading

DDTC and BIS Publish Long-Awaited Final Rules for Category XII: Night Vision and Cameras

On October 12, 2016, the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) published companion final rules to amend Category XII of the United States Munitions List (USML) and move some less sensitive items to the Commerce Control List (CCL).  The final rules will become … Continue Reading

BIS Eases Burma-Related Export Restrictions

On December 23, 2016, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (15 C.F.R. Parts 730-774) to ease export restrictions against Burma consistent with Executive Order 13742, issued in October 2016. That executive order, which we previously have summarized, terminated the national emergency … Continue Reading

DOJ Export Controls and Economic Sanctions Enforcement Guidance Likely to Impact Government Contractors, Parallels FCPA Pilot Program

Members of the Steptoe International Regulation and Compliance team, Tom Best, Jack Hayes, Andy Irwin, Ed Krauland, and Lucinda Low co-authored “DOJ Export Controls and Economic Sanctions Enforcement Guidance Likely to Impact Government Contractors, Parallels FCPA Pilot Program” for Thomson Reuters Briefing Papers (No. 16-12).  The paper discusses a memorandum by the US Department of … Continue Reading

BIS Again Extends ZTE Temporary General License

On November 18, 2016, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it extended its temporary general license for exports, reexports, and in-country transfers to Zhongxing Telecommunications Equipment Corporation (ZTE Corporation) and ZTE Kangxun.  The temporary general license benefitting these two ZTE entities was scheduled to expire on November 27, 2016, … Continue Reading

What a Trump Administration Could Mean for International Regulatory Compliance

After the November 8, 2016 elections, Washington is preparing for a new Congress and the transition of power from eight years of the Democratic Obama administration to the Republican administration of President-elect Donald Trump.  As the incoming president builds his transition team and sets out his policy priorities, Steptoe will examine what these changes may … Continue Reading

Proposed DoD Rule on Protection of Unclassified Technical Data Would “Disqualify” Contractors with Export Violations

On October 31, 2016, the Department of Defense (DoD) published a proposed rule entitled, Withholding of Unclassified Technical Data and Technology from the Public Disclosure.  Public comments must be submitted by December 30, 2016. The proposed rule establishes DoD policy, assigns responsibilities, and prescribes procedures for the circulation and withholding of certain unclassified technical data and … Continue Reading
LexBlog