Hogan Lovells Publications | International Trade Alert | 10 September 2019
State Department signals increased focus on surveillance technology and human rights abuses
On 4 September 2019 the U.S. State Department issued "Draft 'U.S. Government Guidance for the Export of Hardware, Software and Technology with Surveillance Capabilities and/or parts/know-how'" (draft guidance).
Although the draft guidance does not specify any particular government's use of surveillance technology, the release of this document is consistent with the Trump administration's recent focus on the use of surveillance by certain governments against civilian populations in trouble spots around the world. This guidance is not mandatory for export control and sanctions compliance purposes, but it is relevant for companies to consider in building and enhancing their compliance programs.
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