Effective June 29, 2020
The Bureau of Industry and Security (“BIS”) published new export control regulations in an effort to tighten restrictions on exports of technology to China, Russia, Venezuela and Hong Kong. These actions are intended to combat efforts by entities in these countries to use certain U.S. technologies obtained through civilian supply chains or under civilian-use pretenses to develop weapons, military aircraft, and surveillance technology contrary to U.S. national security interests. More specifically BIS has:
- Removed or changed certain license exceptions
- Expanded military end use and end user controls for China, Russia, Venezuela and Hong Kong.
- Broadened the list of items covered by military end use and end user license requirements. See Supplement No.2 to Part 744 for a complete list of items covered.
- Imposed mandatory Electronic Export Information (“EEI”) filing requirements for exports to China, Russia, Venezuela or Hong Kong.
What does this mean to Berkeley Lab?
These changes will impose export licensing and export filing requirements for certain exports to China, Russia, Venezuela and Hong Kong, with a licensing policy of presumption of denial for items intended for military end use or end user.
What actions should you take?
- Be mindful of activities related to military end use or end user in China, Russia, Venezuela and Hong Kong, and contact the Export Compliance Office (“ECO”) for guidance
- Know Your Collaborator/Customer
- Perform restricted party screening using Descartes Visual Compliance prior to engaging in collaborations or activities. For additional due diligence, use Unitracker link provided here: https://unitracker.aspi.org.au/.
Any questions related to this communication can be directed to the Export Compliance Office at firstname.lastname@example.org.