The US Department of Commerce's Bureau of Industry and Security (BIS), the Department of the Treasury's Office of Foreign Asset Control (OFAC), and the Department of Justice have issued a joint compliance note on the use of third-party intermediaries or transshipment points to evade Russian and Belarusian-related sanctions and export controls. The note highlights the most common tactics used to evade these controls and provides guidance to companies on how to maintain an effective, risk-based sanctions and export compliance program.

The following is an excerpt from the article, available in full at the Strategic Trade Review.

The Washington Post today published an investigation showing that US-origin software is central to China’s hypersonic missile development. This is part of a broader trend in which US originated technology, including semiconductors, have been exported to key strategic end uses in China.

Earlier today the Bureau of Industry and Security (BIS) announced an interim final rule to be fully released on October 13th. The rule will amend the EAR for controls on “controls on advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items” as it relates to China. This is paired with a renewed emphasis on controls targeting supercomputer and semiconductor manufacturing end uses.

CNS’s office in Washington, DC today launched a website focused on export control compliance topics. CNS in DC is undertaking research into export controls for emerging technology controls, particularly in the context of strategic competition. As part of that research, the DC office has developed guidance for several emerging technology sectors on how best to ensure compliance with export controls and nonproliferation aims more broadly. A central purpose of the website therefore is to distill the sectoral guidance generated as a result of this research.