Expansion of export controls on China, Russia, and Venezuela

In the last few months, the United States has announced new rules that will significantly expand export restrictions on China, Russia, and Venezuela. On 28 April the U.S. Department of Commerce Bureau of Industry and Security (BIS) published a highly-anticipated final rule that further tightens controls on exports, reexports and in-country transfers to military end users and end uses in China, Russia, and Venezuela. It also issued a final rule withdrawing License Exception CIV for these countries. These final rules go into effect on 29 June 2020.

On 15 May, BIS issued an interim final rule, effective immediately, that significantly expands the foreign direct product rule to cover additional foreign-produced items destined to Huawei. And while these rules tighten restrictions on exports, reexports and in country transfers of certain controlled items and technology, there are also significant implications for companies that export EAR99 items and technology.

Hogan Lovells and Massachusetts Export Center hosted a webinar on Thursday, 18 June to provide specifics on the new requirements under the rules and how they will impact your company. Ajay also discussed ways to mitigate compliance risk through licensing, export reporting, screening and KYC due diligence.

Watch here

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