It’s just a little over a year ago that the Uyghur Forced Labor Prevention Act became law. From all appearances, Customs and Border Protection has been diligent in enforcing its prohibitions and those of 19 U.S.C. § 1307.  According to the agency, “In November 2022, CBP identified 444 entries valued at more than $128 million for further examination based on the suspected…
The Unverified List, the Commerce Department’s listing of foreign companies subject to restrictions on all items included in the Export Administration Regulations, has received increased attention as a result of the recent addition of 33 Chinese industrial and technology companies to the list. Read how George Thompson, International Trade Attorney, explains what the Unverified List…
The Bureau of Industry and Security recently published expanded export control sanctions on Russia and others. Industry sector controls on Russia have been extended to Belarus, and the military end-use/end-user controls have been expanded to include surreptitious suppliers to parties covered by the MEU license requirement. The BIS rule now expands the military end-user controls…
The Bureau of Industry and Security (BIS) has adopted a new administrative enforcement approach for resolving export control violations. BIS anticipates it will result in the imposition of substantially higher monetary penalties for egregious cases, while also providing for non-monetary resolutions of less serious ones. It was implemented to address evasions of the ever-growing…
The Uyghur Forced Labor Prevention Act (UFLPA) went into effect on June 21, 2022. The UFLPA has three key provisions: It creates a rebuttable presumption that all items produced, in whole or in part, in the Xinjiang region of China are made with forced labor. It requires Customs and Border Protection to create an…
Buy American Rules Update There have been fairly significant changes to the Buy American rules under both the Federal Acquisition Regulation, or FAR, and the Defense Federal Acquisition Regulation Supplement, or DFARS. They relate to when a product qualifies as a domestic end product, and thereby is eligible for the Buy American bidding preference….
The Federal Trade Commission’s Made in the USA Rules A notice appeared in the May 19th Federal Register detailing a consent agreement reached with a company called Lions Not Sheep over what the Federal Trade Commission alleged were false and misleading statements regarding the origin of their products. In the following transcript,…
Sanctions imposed on Russia by the BIS The February 24 sanctions imposed on Russia by the BIS have put in place a vastly expanded definition of the foreign-direct product rule, which will pose significant compliance challenges. In the following transcript George Thompson details which products are affected by the new rule and how…
The Unverified List The Commerce Department’s listing of foreign companies subject to restrictions on all items included in the Export Administration Regulations, has received increased attention as a result of the recent addition of 33 Chinese industrial and technology companies to the list. The following transcript from George Thompson‘s video, explains what the Unverified…
The Foreign-Direct Product Rule is a provision of the Export Administration Regulations The following transcript from George W. Thompson, explains the criteria under which some foreign products are subject to the EAR and are thereby within the scope of export controls even if they have no physical U.S. origin content. Hello again, this is…