Author: Megan Mohler


Overview of BIS’s Interim Final Rules, Export Controls for Advanced Computing, Supercomputing, and Artificial Intelligence

By: Megan Mohler, Associate Attorney

On October 25, 2023, the Bureau of Industry and Security (“BIS”) published interim final rules amending the Export Administration Regulations (“EAR”) to add/clarify new controls on semiconductor manufacturing equipment (“SME”), advanced computing integrated circuits (“IC”), and computer commodities containing them.

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Russia remains one of the world’s top aluminum producers

Recent U.S. Actions Affecting Imports of Aluminum Products and More from Russia

By: Megan Mohler, Associate Attorney

With the signing of two recent Presidential Proclamations, the U.S. has chosen to take another hardline stance on Russia from an import perspective. Currently, Russia remains one of the world’s top aluminum producers, among other base metals and ore producers. This is troublesome for U.S. importers who still import base metals or derivative metal products from Russia, specifically aluminum.

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Prior disclosure

2022: Prior Disclosure Woes

By: Megan Mohler, Associate Attorney, Braumiller Law Group

The year is 2022, and companies are turning over a new leaf, making a concerted effort to become compliant with U.S. Customs laws and practices. Seemingly, there are no downsides to conducting a comprehensive Customs compliance review and submitting a Prior Disclosure under 19 U.S.C. § 1592(c)(4) and 19 C.F.R. § 162.74.

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icts Information and Communications Technology and Services

ICTS Transactions Rule Includes Imports and Uncertainty

By Attorneys, Megan Mohler and Vicky Wu, Braumiller Law Group

On January 19, 2021, the U.S. Department of Commerce published an interim final rule (interim rule) and proposed regulations (15 CFR Part 7) that could, effectively, mean a new licensing regime on imports related to Information and Communications Technology and Services (ICTS).

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