Top Story

Development Finance More than China, Reps. Told

Rep. Kathy Manning (R-MO) chaired the hearing
U.S. International Development Finance Corp. Chief Executive Scott Natan met with the House Foreign Affairs Committee Tuesday to discuss the "DFC's Efforts to Out Compete China's Belt & Road Initiative," as the committee looks to prepare funding for FY 2025. Rep. Kathy Manning (D-NC) cautioned members against viewing the DFC only as a tool to promote rivalry with the PRC.  "We cannot be seen as a reliable partner if our motivations are viewed only through the prism of some great power competition, or if we only show up when we need something.
Royal Australian Navy Collins Class Submarines joined in formation by United States Navy Los Angeles Class Submarine USS Santa Fe in the West Australian Exercise Area for a photo opportunity in February 2019.
AUKUS: State Issues ITAR Rules
Following on the Commerce Department's modification of dual-use export controls for alliance partners [Link],  the US Departemnt of State proposes to amend the International Traffic in Arms Regulations (ITAR) to support the goals of the AUKUS partnership. The Department is proposing an ITAR amendment in the interest of preparing for a future exemption and obtaining public feedback to shape a final rule following any positive certification.
Carrie Furnace, Homestead, PA
U.S. Steel Sale to Japanese Under Siege
It is premature to declare Nippon Steel's bid to buy US Steel dead,, despite election year politics driving acerbic scrutiny from Labor and legislators. Tuesday, the United Steelworkers scoffed at Nippon Steel's overtures to the union, calling them "nothing more than another collection of empty promises and open-ended language that would enable it to skirt obligations to workers and retirees."
Private sales to countries like Kyrgyzstan, Laos, Mali and Yemen will be declined.
Commerce Acts on Firearms "Pause"
Friday the Department of Commerce released an interim final rule amending the Department’s licensing policy for exports of firearms, ammunition, and related components under its jurisdiction. Coming on the six-month anniversary of a controversial "90 day pause" in firearms export license approval, the new rule proposes significant changes.

Welcome to your new Export Practitioner

The Export Practitioner introduces a web-based format for easier review, research and sharing.  

In addition to your monthly print or e-edition, we can furnish mid-month updates for our readers. 

We seek your input as we make this transition. Please send your suggestions to fruffing@traderegs.com or call 703.283.5220.   

– Frank Ruffing, Editor 

Our latest news

BIS Antiboycott Advisory on Türkiye

In response to Ankara's suspension of trade with Israel,The US Department of Commerce's Bureau of Industry and Security (BIS) has issued an antiboycott advisory on Turkey. U.S. companies operating in Türkiye, in particular, are cautioned to be alert to their receipt of any requests to refrain from importing or exporting goods to or from Israel or to provide certification that the goods are not of Israeli origin or do not contain Israeli-origin components or materials. 

AML/CFT Treasury Strategy Released

The Treasury Department issued the 2024 National Strategy for Combatting Terrorist and Other Illicit Financing , which provides a blueprint of the U.S. government’s goals, objectives, and …

More Sudan Rebel Leaders Sanctioned

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Ali Yagoub Gibril and Osman Mohamed Hamid Mohamed, pursuant to Executive Order (E.O.) 14098, for leading the Rapid Support Forces’ (RSF) war campaign. The RSF’s attacks in North Darfur, which started last month, have caused dozens of civilian casualties, including children.

More Sanctions for DPRK - Russia Arms Traders

Treasury’s Office of Foreign Assets Control (OFAC) is imposing sanctions on two Russian individuals and three Russia-based entities for facilitating weapons transfers between Russia and the Democratic People’s Republic of Korea (DPRK).

DHS Lists More Chinese Cotton Traders

The Department of Homeland Security (DHS) announced the addition of 26 textile companies based in the People’s Republic of China (PRC) to the Uyghur Forced Labor Prevention Act (UFLPA) Entity …

White House Boots Chinese Crypto Miner

Monday President Biden issued an order prohibiting the purchase and requiring the divestment of certain real estate operated as a cryptocurrency mining facility located within one mile of Francis E. Warren Air Force Base, as well as requiring the removal of certain improvements and equipment at the property. MineOne acquired the property in June 2022 and then made improvements to allow for use of the property for specialized cryptocurrency mining operations within one mile of F.E. Warren AFB in Cheyenne, Wyoming, a strategic missile base and home to Minuteman III intercontinental ballistic missiles.  
Enforcement
The Disruptive Technology Strike Force meets with US government and private sector partners to discuss the threat to advanced U.S. technology from hostile foreign governments and its efforts to …
A Florida woman pleaded guilty to 25 felony counts in Florida federal court, related to a scheme to falsely represent parts manufactured by a debarred Turkish fabricator were of American Origin. Among violations were the export of sensitive military drawings and specifications, despite the clear warnings on the face of each drawing that it could not be exported without obtaining a license.
U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Advisory to assist financial institutions in detecting potentially illicit transactions related to …
Sanctions
Vancouver-based Calibre Mining, the largest miner in Nicaragua was not sanctioned.

US Sanctions Nicaraguan Gold Miners and Russian Training Center

Treasury is imposing sanctions on three Nicaragua-based entities, the Training Center of the Russian Ministry of Internal Affairs in Managua (RTC); Compania Minera Internacional, S.A. (COMINTSA); and Capital Mining Investment Nicaragua, S.A. The RTC is a Nicaragua-based subdivision of the Government of the Russian Federation’s (GOR) Ministry of Internal Affairs, and is a "key actor in the Nicaraguan regime’s repression of civil society and unjust detention and imprisonment of individuals for expressing dissent, or otherwise peacefully exercising their human rights and fundamental freedoms," according to the OFAC statement. The designations of COMINTSA and Capital Mining target government-affiliated gold companies generating revenue for the Ortega-Murillo regime. Gold is Nicaragua’s top commodity export.

Treasury Stops Austrian Deal with Oligarch, Sanctions Parties

Treasury’s Office of Foreign Assets Control (OFAC) designated one Russian individual and three Russia-based companies involved in an attempted sanctions evasion scheme in which an "opaque and …

BIS Adds Chinese Nuclear, Aviation, Quantum Entities to Blacklist

The Commerce Department’s Bureau of Industry and Security added 37 entities – mostly based in China – to the Entity List under the Export Administration Regulations.  BIS said the action, announced Thursday, reflects the Administration’s commitment to safeguarding US national security and foreign policy interests.
Policy Briefs
A bill has been introduced in Congress to close a loophole in U.S. export control laws that is being exploited by China, according to its sponsors.   The Remote Access Security Act will ensure …
House China Hawks introduced the “Enhancing National Frameworks for Overseas Critical Exports Act” (ENFORCE Act), modifying the Export Control Reform Act of 2018 (ECRA) The ENFORCE Act amends ECRA to give BIS the authority to export control-covered AI systems.
A bipartisian group of lawmakers has introduced  BIOSECURE Act, a bill to ensure American patient data and taxpayer dollars do not fall into the hands of foreign adversaries' biotechnology companies of concern by prohibiting Federal contracting with these companies. The Chinese Communist Party's (CCP) national security laws require all Chinese firms to share any requested data with the CCP, including biotechnology companies that collect, test, and store American genomic data.
Supply Chain
Drones for First Responders (DFR) Act will  implement a new tariff on Communist Chinese-controlled drones and use the tariff revenue to establish a new grant program to help first responders, …
The President signed H.R. 1042, the Prohibiting Russian Uranium Imports Act, into law May 13, 2024.  This bipartisan legislative action prohibits the import of Russian uranium products into the United States as of August 12, 2024, while enabling a waiver process with the Department of Energy, in consultation with the Departments of State and Commerce, through January 1, 2028, consistent with the law.    May 14, 2024   The President signed H.R. 1042, the  Prohibiting Russian Uranium Imports Act , into …
Ambassador Katherine Tai issued a statement Monday regarding the   finding against the United States in a determination regarding a labor dispute at the San Martin lead, zinc, copper and silver mine in the Mexican state of Zacatecas: The Rapid Response Labor Mechanism (RRM) panel established under the United States-Mexico-Canada Agreement (USMCA) determined that the agreement had no jurisdiction in the decades long labor dispute.
Licensing
Since Russia’s full-scale invasion of Ukraine in February 2022, Chinese exports to Russia have risen by more than 60 percent .  Nathaniel Sher writes in Canegie Politika (link) that this trade is "nothing short of a lifeline to Russia's economy."
Directorate of Defense Trade Controls, Bureau of Political Military Affairs, Department of State (T/PM/DDTC) is surveying Individuals and companies registered with DDTC and engaged in the business of manufacturing, brokering, exporting, or temporarily importing defense hardware or defense technology data.   The information collection in question is the Statement of Material Change, Merger, Acquisition, or Divestiture of a Registered Party.
A bipartisan group of senators have introduced legislation aimed at expanding the Australia- United Kingdom-United States partnership to include Japan in order to combat the growing threat of China. The Coordinating AUKUS Engagement with Japan Act directs the two AUKUS coordinators at the U.S. Departments of State and Defense to engage with Japan, and consult with counterparts in the U.K. and Australia, at technical level to better understand how Japan could augment the partnership and what steps Japan might need to take in order to engage quickly and meaningfully in AUKUS advanced technology projects.
BIS Publishes final rule making conforming and clarifying changes to the Export Administration Regulations (EAR). These changes include making conforming changes to the EAR to ensure that destination names reflect the current destination names that are recognized by the United States Government, clarifying the removal of certain license requirements for exports, reexports, and transfers (in-country) to and within Australia and the United Kingdom, making a conforming change to reflect that Cyprus is no longer a Country Group D:5 country, and clarifying how Russia and the Russian Federation are referenced for consistency with the designation of Russia as a U.S. Arms Embargoed destinations.
Reuters reports the Commerce Department is considering a new regulatory push to restrict the export of proprietary or closed source AI models There are currently no restrictions on the sale of AI models to foreign adversaries, presenting a potential national security risk.