On May 26, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule revising the restrictions on the export, reexport and transfer (in-country) of certain “cybersecurity items” used for malicious cyber activities (“final rule”). Effective immediately upon publication, the final rule amends the October 21, 2021, interim final rule
Gretel Echarte Morales
OFAC Imposes First-Ever Sanctions Against Virtual Currency Mixer
On May 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated crypto mixer Blender.io as a Specially Designated National (“SDN”), marking the first time a virtual currency mixer has been sanctioned. The move is the latest in a series of sanctions designations and enforcement actions in the virtual currency…
US Commerce Issues Rules for Review of ICTS Transactions for National Security Threats
On January 19, 2021, the US Department of Commerce (“Commerce”) issued a long-awaited interim final rule (“Interim Final Rule”),1 which would enable Commerce to prohibit or otherwise restrict transactions involving the information and communication technology and services (“ICTS”) supply chain, including both hardware and software, that have a nexus to certain designated “foreign adversaries,”…
BIS Considering New Export Restrictions on Facial Recognition Devices and Other Biometric Surveillance Equipment
On July 17, 2020, the US Department of Commerce, Bureau of Industry & Security (“BIS”), published a Notice of Inquiry (“Notice”)1 seeking public comments on potential changes to items controlled for crime control and detection (“CC”) reasons under the Export Administration Regulations (“EAR”)2 and the related licensing requirements. Among other possible changes, BIS…
Staying Ahead of the Curve: Cybersecurity and Data Privacy–Hot Topics for Global Businesses
Cyber threats continue to evolve, and data privacy considerations continue to grow more complex. Whether defending against global ransomware campaigns or adjusting to new legal regimes governing international data transfers, companies of all sizes today face unprecedented cybersecurity and data privacy challenges.
Our practical guide, Staying Ahead of the Curve: Cybersecurity and Data Privacy—Hot Topics…
‘Where did my Technical Data Go?’ The Legal Nexus Between Export Control Obligations and Cyber Security Vigilance
In a bylined article, International Trade partner Tamer Soliman, Cybersecurity & Data Privacy partner David Simon and Litigation & Dispute Resolution associate Gretel Echarte Morales (all Washington DC) discuss export control obligations and cyber security.