BIS recently moved to tighten exports, reexports, and in-country transfer to China, Russia, and Venezuela. BIS is implementing the '744 Rule' which will expand the licensing requirements when an exporter has knowledge or has reason to know the items will be for Chinese, Russian, and/or Venezuelan military end users or end uses.

BIS announced on April 28, 2020, that they will be amending the EAR to remove License Exception CIV from Export Control Classification Numbers and will now require an export license for national security-controlled items on the CCL to countries of national security concern.

The Directorate of Defense Trade Controls (“DDTC”) announced on April 23, 2020 measures to lessen the burden that the COVID-19 pandemic is having on U.S. companies and the overseas supply chains in order to help the exporting/importing community.

With the COVID-19 pandemic, some companies will become prime targets for acquisitions, mergers and investments. Others may recognize that their survival is in being acquired or merged with existing companies, or in receiving investments to continue. Perhaps it is time to revisit what this means for companies.