On September 30, President Biden signed the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Extension Act of 2022, reauthorizing the SBIR and STTR programs through September 30, 2025.
Continue Reading Register Now | SBIR/STTR Program Reauthorization – Changes Are Coming!
International Trade Enforcement Roundup – October 2022
You are reading Bass, Berry & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles and a bit of our insight to your inbox every month.
October 2022 was an active month for enforcement, with the Department of Treasury updating Committee on Foreign Investment in the United States (CFIUS) guidelines and the Departments of Justice (DOJ) and Commerce (DOC) taking multiple actions. To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our international trade team. We welcome your feedback and encourage sharing this newsletter with anyone who may be interested.Continue Reading International Trade Enforcement Roundup – October 2022
New CFIUS Guidelines Reflect Shift in Enforcement Posture
On October 20, the Committee on Foreign Investment in the United States (CFIUS) released new, non-binding Enforcement and Penalty Guidelines (Guidelines). The Guidelines follow upon last month’s Executive Order linking CFIUS reviews directly to the president’s national security prerogatives. In particular, the Guidelines detail the following:
- Categories of conduct that constitute violations.
- Sources of information CFIUS relies upon to determine whether a violation has occurred.
- The process for developing and imposing penalties.
- Aggravating and mitigating factors that CFIUS evaluates when deciding whether to impose a penalty.
Continue Reading New CFIUS Guidelines Reflect Shift in Enforcement Posture
Register Now | A Multi-Jurisdictional Discussion of Export Controls on China, Russia and Belarus: Contrasting US, UK and EU Restrictions
I will join Brian Mulier (Bird & Bird LLP) and Keith Huffman (SAP) to present a workshop titled “A Multi-Jurisdictional Discussion of Export Controls on China, Russia and Belarus: Contrasting US, UK and EU Restrictions” on Monday, November 14 from 1:30-5:00 pm at the London Forum on Global Economic Sanctions being held at the Millennium Gloucester Hotel.
Continue Reading Register Now | A Multi-Jurisdictional Discussion of Export Controls on China, Russia and Belarus: Contrasting US, UK and EU Restrictions
Register Now | The Ins and Outs of EAR Licensing Exceptions: How to Determine If, When and How They Apply
I will join Lexia Krown, Vice President Global Trade Compliance at ESAB Corporation to present a workshop titled “The Ins and Outs of EAR Licensing Exceptions: How to Determine If, When and How They Apply” on Thursday, October 20 from 1:00-4:30 pm ET as part of the ACI Proficiency Series: Export Administration Regulations.
Continue Reading Register Now | The Ins and Outs of EAR Licensing Exceptions: How to Determine If, When and How They Apply
Russia, Ukraine: Update as of October 3
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Monday, October 3. This post supplements our previous summaries, which are available by following the links at the end of this blog post.
Commerce Adds Iranian Aircraft to List of Aircraft Operated in Violation of the EAR
On September 19, the Commerce Department’s Bureau of Industry and Security (BIS) updated its growing list of aircraft that have flown into Russia and/or Belarus in apparent violation of the Export Administration Regulations (EAR). As discussed previously, these aircraft are essentially off limits for any person to service (or operate), given that nearly any dealing with respect to such an aircraft would violate General Prohibition 10 of the EAR.Continue Reading Russia, Ukraine: Update as of October 3
Russia, Ukraine: Update as of August 9
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Tuesday, August 9. This post supplements our previous summaries, which are available by following the links at the end of this blog post.
Treasury Targets Broad Range of Entities in Recent Round of Sanctions
On August 2, acting pursuant to Executive Order 14024, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions designating members of the Russian elite, a multinational corporation, and sanctions evaders.Continue Reading Russia, Ukraine: Update as of August 9
Chipping Away at Trade: New Tool Could Bring Big Changes
On August 9, President Biden plans to sign the CHIPS and Science Act into law in the White House Rose Garden. The bill provides $52.7 billion in subsidies and incentives to domestic semiconductor manufacturers to strengthen existing supply chains and better compete with China. While details of the bill have been debated as the legislation has gone through multiple rounds of revisions and edits, elected officials have remained focused on the goal of enacting a bill that ensures funding to promote domestic rather than non-U.S. business. To realize those ambitions, the legislative authors took a page from the Committee on Foreign Investment in the United States’ (CIFUS) playbook, producing a quasi-outbound investment screening mechanism that could bring big changes.
Continue Reading Chipping Away at Trade: New Tool Could Bring Big Changes
Russia, Ukraine: Update as of July 7
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Thursday, July 7. This post supplements our previous summaries, which are available by following the links at the end of this blog post.
Commerce Department Continues to Target Airlines, Entities; OFAC Extends Sanctions to New Parties, Imports of Gold
On June 24, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued Temporary Denial Orders (TDOs) against an additional three Russian airlines: Nordwind Airlines, Pobeda Airlines, and S7 Airlines. BIS cited apparent ongoing violations of the comprehensive export controls imposed on Russia. Under these TDOs, the airlines are banned from participating in transactions subject to the Export Administration Regulations (EAR), including exports from the United States and re-exports from abroad. The TDOs initially run for 180 days but will likely be extended.Continue Reading Russia, Ukraine: Update as of July 7
Update on FCPA Enforcement: First Half of 2022 Sees Major Enforcement Action
Since late March, the U.S. government has announced several significant enforcement actions under the Foreign Corrupt Practices Act (FCPA), the main U.S. law that prohibits bribery of non-U.S. government officials.
Often working in coordination with its enforcement counterparts in other parts of the world, the U.S. Justice Department (DOJ) and Securities & Exchange Commission (SEC) have resolved three notable matters against companies, and pursued one individual enforcement matter. The alleged bribery involved in these matters occurred in multiple countries in Africa and South America.Continue Reading Update on FCPA Enforcement: First Half of 2022 Sees Major Enforcement Action