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Many of us are just trying to keep our head above water with the changing compliance scene. Such is the case with the recent announcement from the Department of Commerce stating that they are issuing an interim final rule allowing persons to share certain U.S. technology with Huawei.

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.