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Insights

Export controls and sanctions

BIS, the EAR, OFAC, the Entity List and ITAR.

  • What CBP’s New Supply Chain Visibility Proposal Means for Importers

    Shanshan Liang

    On September 2, 2026, U.S. Customs and Border Protection (CBP) issued a landmark Advance Notice of Proposed Rulemaking (ANPRM) under Docket No. USCBP-2026-1058. The notice directly supports Executive Order 14411, “Strengthening Customs…

  • New U.S. Sanctions on Mexico

    Shanshan Liang · Presentation

  • BIS Clarifies Advanced Computing Export Controls: China-Linked Entities Remain Subject to Licensing Requirements

    Johnathan Foege

    The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has issued new guidance reaffirming an important principle that many exporters, distributors, and technology companies may have misunderstood following the…

  • U.S. Government Orders Suspension of Anthropic’s Fable 5 and Mythos 5 Models: What It Means for AI Governance and Compliance

    Johnathan Foege

    The intersection of artificial intelligence and national security continues to evolve rapidly, and a recent government action involving Anthropic’s newest AI models demonstrates the increasing scrutiny frontier AI systems face from…

  • Strait of Hormuz Closure- What You Need to Know

    Shanshan Liang

    On February 28, 2026, geopolitical tensions in the Middle East escalated sharply following an Iranian attempt to close the Strait of Hormuz. The situation has rapidly evolved from diplomatic warnings to active kinetic conflict, severely…

  • U.S.–China Announce Tariff Suspensions and New Trade Understandings

    Johnathan Foege

    China’s Ministry of Commerce announced that the latest round of U.S.–China economic and trade talks, held in Kuala Lumpur, resulted in several notable tariff and export-control suspensions that could temporarily ease tensions for…

  • BIS Issues Interim Final Rule Extending Entity List Restrictions To 50% Ownership

    Johnathan Foege

    On September 29, 2025, the Bureau of Industry and Security (BIS) implemented an interim final rule (IFR) amending the Export Administration Regulations (EAR) to broaden the reach of the Entity List. Published at 90 FR 47201, this rule…

  • Peace Agreements and New Trade Corridor Could Reshape the South Caucasus and Central Asia’s Economic Future

    Johnathan Foege

    On August 8, 2025 the White House announced a U.S.-brokered peace agreement between Armenia and Azerbaijan that carries serious implications for international trade. Alongside the peace declaration, the parties signed bilateral economic…

  • OFAC Sanctions 18 Hong Kong Companies for Alleged Involvement in Iranian Oil Trade

    Johnathan Foege

    On July 9, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a new round of sanctions targeting 22 companies based in Hong Kong, the United Arab Emirates, and Turkey. Among them, 18 companies…

  • U.S.-Colombia Tariffs and Sanctions: status update

    Johnathan Foege

    A standoff between the United States and Colombia ended Sunday night with an agreement between the two countries. Even so, until further notice Columbian cargo may be subject to heightened scrutiny by U.S. Customs and Border Protection.…

  • 27 Companies Added To BIS Entity List

    Johnathan Foege

    On January 16, 2025, the United States Department of Commerce, Bureau of Industry and Security (“BIS”) published the names of 25 Chinese entities and 2 Singapore entities that are added to the Entity List (the “List”) under 15 CFR §…

  • 32 Chinese Entities Among 250 Sanctioned By State and Treasury Departments

    Johnathan Foege

    On January 15, 2025, the U.S. Department of State (“State”) and the U.S. Department of Treasury (“Treasury”) have jointly imposed sanctions on over 250 entities and individuals. The sanctions partially focus on Chinese entities which…

  • 39 Chinese Companies Added To DHS Entity List

    Johnathan Foege

    On January 15, 2025, the United States Department of Homeland Security (“DHS”) added 39 companies to the Entity List (the “List”) under the Uyghur Forced Labor Prevention Act (“UFLPA”). Entities on the list are those entities working…

  • China Bans Rare Earth Metal Exports To United States: What Now?

    Johnathan Foege

    New export bans as, on Tuesday, December 3 Chinese officials announced an escalation to trade restrictions between China and the United States. Specifically, China has placed a ban on all sales of gallium, germanium, antimony, tungsten…

  • Latest UFLPA Entity List Updates: Compliance and Challenges

    Neil B. Mooney

    On May 16, 2024, the Biden administration added 26 Chinese companies to the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List, primarily targeting the textile industry. This action reflects ongoing efforts to enforce supply chain…

  • OFAC to consider COVID-19 issues when addressing “apparent violations” of its regulations

    Neil B. Mooney

    The Office of Foreign Assets Control, often one of the most difficult and implacable federal agencies to deal with, has announced its intent to consider COVID-19 issues when addressing “apparent violations” of its regulations. In a…

  • Changes to Cuban Policy

    Neil B. Mooney

    The Trump administration is tightening restrictions on travel, trade, and remittances to Cuba. The new changes are as follows: Vessels and aircrafts initially authorized to fly to Cuba on temporary sojourn will no longer be able to.…

  • OFAC Enforcement Against Va. Forwarder and Fl. Shipper

    Neil B. Mooney

    I. Virginia Forwarder The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Finding of Violation to DNI Express Shipping Company (“DNI”), incorporated in McLean, Virginia, for a violation of § 501.602 of…

  • UPDATE- Section 301 (Tranche 3) Duties as of May 10, 2019

    Neil B. Mooney

    Yesterday, May 9, 2019, U.S. Customs and Border Protection (“CBP”) clarified that the Section 301 tariffs apply only to merchandise exported on or after May 10, 2019. Today, May 10, 2019, CBP provided updated guidance of the following…

  • Have A Billion Dollar Export Penalty? Let’s Not.

    Neil B. Mooney

    This is an old blog we lost during our transfer of site hosting. A record-setting payment of $1,190,000,000.00 by ZTE Corporation of Richardson, Texas (“ZTE”) shows the enormous risks today of underestimating U.S. export enforcement.…

  • When the Broker Must be the Importer of Record

    Neil B. Mooney

    The Importer of Record, or “IOR” has a lot of liability for entry. Any penalties resulting from discrepancies relating to classification of the goods or admissibility issues, and the duties to be paid, must be covered financially by the…

  • 2016: The Year of Cuba

    Neil B. Mooney

    2016 has kicked off with some big changes, many of which pertain to the United State’s relationship with Cuba. On January 27th, 2016, the Bureau of Industry and Security (BIS) and the Office of Foreign Assets Control (OFAC) announced…

  • New BIS Export Enforcement Guidelines

    Neil B. Mooney

    As we start off this new year there are some important new changes to be aware of; this includes the Bureau of Industry and Security’s (BIS) proposed changes to export enforcement guidelines. This bureau is the agency responsible for…

  • Transitioning to the ACE Portal

    Neil B. Mooney

    There is continual automation in the world of forwarding. One change this week is the integration of the Automated Export System (AESDirect) into the Automated Commercial Environment (ACE) Portal. Until recently, AESDirect has been the…

  • Confidential Export Information

    Neil B. Mooney

    It is always important to ensure that you are completing international shipping documentation accurately. One of the documents required for each single commodity exported having a value exceeding $2,500 is a Shipper’s Export Declaration…

  • Cuba Travel: What You Need to Know

    Neil B. Mooney

    On September 21st, 2015 the Obama administration implemented numerous regulatory changes aimed at loosening U.S. business and travel restrictions relating to Cuba. Americans can now open business locations and bank accounts in Cuba, and…

  • Surprise! Reestablishment of US Trade, Travel, and Diplomatic Ties with Cuba

    Neil B. Mooney

    Today President Obama announced a change in US policy intended to reopen diplomatic, economic, and cultural ties between the nations. The United States will establish an embassy in Havana, and issue licenses for travel to Cuba for…

  • U.S. Changes in Iranian Sanctions Regime

    Neil B. Mooney

    As I’m sure many, if not all, of you are aware, the US with the EU and United Nations have recently undergone successful negotiations with Iran in order to reach “mutually-agreed long-term comprehensive solution that would ensure Iran’s…

  • Panama Canal Expansion: What Does it Mean for Florida?

    Neil B. Mooney

    The Panama Canal Expansion project (also called the Third Set of Locks Project) is projected to be completed in April of 2015. The project was announced with the purpose of increasing Panama’s ability to benefit from the growing traffic…

  • TRADE POLICY: OBAMA vs ROMNEY

    Neil B. Mooney

    International trade is vital to our economy, so much of the debate in the upcoming Presidential election has surrounded the candidates’ foreign trade policies. President Barack Obama (D) and his challenger, Governor Mitt Romney (R),…

  • Resources for Exporting: A Visit to the Mississippi Gulf Coast

    Neil B. Mooney

    Last week I visited the beautiful Mississippi Gulf Coast to attend the Gulf States Trade Alliance’s 2012 Annual Export conference from April 10-12 at the Beau Rivage Resort. The theme for the event was “Export Resources and New Market…

  • Free Trade Agreement Series: Part 4- The New Korean Market and Rules of Origin

    Neil B. Mooney

    A free trade agreement approximately six years in the making is now a reality for Korea and the United States. Just as with other FTAs, this new market access allows for reduced and sometimes eliminated tariff rates and quotas as well…

  • Free Trade Agreement Series: Part 2- Importer Requirements Under NAFTA

    Neil B. Mooney

    Having originated nearly 20 years ago NAFTA, is a well established free trade agreement that continues to have a significant impact on importers and exporters. In efforts to open global markets to U.S. businesses, the U.S. government…

  • Free Trade Agreement Series: Part 1- Exporter Requirements Under NAFTA

    Neil B. Mooney

    When you are preparing to export goods to Mexico or Canada (“NAFTA Countries”), you are likely going to seek preferential treatment of your goods under NAFTA. However, before you ship the goods to your buyer, make sure you are familiar…

  • Customs Seizure Benefits Florida

    Neil B. Mooney

    In August 2008, a piece of America’s aviation history, the Douglas AD-4N Skyraider*, reentered its home territory under false pretenses, which ultimately led U.S. Customs and Border Protection (CBP) agents to seize the aircraft nearly a…

  • Transshipment under the Export Administration Regulations: An Attempt to Get Around the Regulations Ends Badly For a Florida Company

    Neil B. Mooney

    The Export Administration Regulations (EAR), at Part 736, General Order No. 2 of Supplement No. 1, prohibits export of all items covered by the EAR to Syria unless they are licensed shipments of food or medicine. This broad prohibition…

  • August A Busy Month For Export Control Regulation Amendments: Changes to the ITAR Dual-National Rule and Commodity Jurisdiction Process

    Neil B. Mooney

    The Obama Administration’s ongoing effort to simplify the complex maze of export regulatory regimes, dubbed the Export Control Reform initiative, has given rise to a proposed amendment to the International Traffic in Arms Regulations…

  • Freight Forwarder Settles Charge of Antiboycott Violation for Furnishing Negative Certification of Origin on Shipper’s Invoice

    Neil B. Mooney

    Most trade intermediaries are familiar with the antiboycott provisions contained in Part 760 of the Export Administration Regulations (EAR). These regulations prohibit U.S. persons’ participation in or cooperation with the Arab League’s…

  • The Department of Commerce’s Bureau of Industry and Security Updates Its Freight Forwarder Guidance

    Neil B. Mooney

    The Department of Commerce’s Bureau of Industry and Security (BIS) recently posted new export control guidance for freight forwarders on its website. BIS enforces the Export Administration Regulations, which regulate the conduct of both…

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