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In an Advance Notice of Proposed Rulemaking (ANPRM) published in the Federal Register on Monday, March 29, 2021, Commerce announced that it is soliciting public comment on a licensing process for companies seeking pre-clearance for information and communications technology and services (ICTS) transactions subject to Commerce’s broad new authority to block or unwind such transactions, as implemented in the interim final rule, “Securing the Information and Communications Technology and Services Supply Chain.” That interim final rule, which was published on January 19, 2021, became effective on Monday, March 22, 2021, and broadly defines transactions to include acquisition, importation, transfer, installation, dealing in or use of ICTS. We previously discussed that interim final rule here.
Continue Reading Commerce Publishes ANPRM Seeking Comment on the Licensing Process for ICTS Transactions

Today, Commerce has published an interim final rule (IR) which, effective March 22, 2021, will implement the May 15, 2019 Executive Order 13873 that relied on the International Emergency Economic Powers Act (IEEPA) to authorize sweeping power to block or undo any transaction – including use, purchases or importation – of virtually any “information and

On August 10, the Federal Emergency Management Agency (FEMA), under the Department of Homeland Security, will be extending and revising a Temporary Final Rule (first issued in April this year) that invokes the Defense Production Act (DPA) to allocate certain Personal Protective Equipment (PPE) for domestic use and prohibit exportation of that PPE from the

We are excited to announce our Export Controls Classroom webinar series. This monthly series open to all will cover a range of topics from the nuts and bolts of export compliance, to in-depth analysis of emerging issues, and will be designed for those new to export controls and as well as more experienced compliance and

On May 21, 2020, Treasury proposed to change its approach for identifying which foreign investment in a U.S. business will trigger the requirement for mandatory notification to the Committee on Foreign Investment in the U.S. (CFIUS). With respect to covered transactions involving U.S. businesses which produce, design, test, manufacture fabricate or develop those “critical technologies”

The Committee on Foreign Investment in the US (CFIUS) has announced an Interim Final Rule requiring payment of filing fees in connection with any Joint Voluntary Notices submitted on or after May 1, 2020 for “covered transactions” under 31 C.F.R. Part 800 or for “covered real estate transactions” under Part 802. The Interim Final Rule

The Federal Emergency Management Agency (FEMA), under the Department of Homeland Security, has released a Temporary Final Rule that invokes the Defense Production Act (DPA) to allocate certain Personal Protective Equipment (PPE) for domestic use and prohibit exportation of PPE from the U.S. without express FEMA approval. The mechanics of implementation remain somewhat unclear, but

On March 4, 2020, the Department of Treasury released a proposed rule to implement section 1723 of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) and require filing fees on voluntary notices to the Committee on Foreign Investment in the United States (CFIUS) for transactions that exceed $500,000. No fee will be required

The Trump Administration’s first 100 days shed little light on how it will reconcile an America First trade policy with insistence on more robust defense spending by our allies.  On May 5, 2017, at 8:30 AM Eastern, Crowell & Moring attorneys Adelicia Cliffe, Alan Gourley, Yuan Zhou, and Jana del-Cerro will lead a discussion highlighting

On Thursday, August 11th, 2016 at 1 PM Eastern, join our Crowell & Moring attorneys for a webinar entitled: “An Intro to Export Controls, Economic and Trade Sanctions: Understanding and Addressing Risks and Challenges.” During this 90-minute webinar, our experts will clarify how US export control rules specifically affect contractors, subcontractors, suppliers, consultants and manufacturers