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Compliance

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Concern regarding IP theft and other forms of unfair trade practices have been of paramount importance in the past five years in the United States – and have indeed been the justification for imposing significant and long-lasting trade barriers. The Biden Administration affirmed its commitment to using a wide range of remedies to address such trade practices through a set of reports on the 100-day interagency reviews conducted pursuant to Executive Order 14017 “America’s Supply…

On January 19, 2021, the US Commerce Department (“Commerce”) published an interim final rule (“Interim Rule”) to implement Executive Order 13873, “Securing the Information and Communications Technology and Services (“ICTS”) Supply Chain.” The Interim Rule was issued following the public comment period’s closure on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”). For more information on the Proposed Rules and the Interim Rule, please see our blog posts here and here. When it requested comments on…

Introduction In early March of this year, a bipartisan group of members of the House Armed Services Committee formed the Defense Critical Supply Chain Task Force (the “Task Force”). Co-chaired by House Democrat Elissa Slotkin (Michigan) and Republican Mike Gallagher (Wisconsin), the Task Force was formed to address what has been perceived as U.S. overreliance on vulnerable defense supplies manufactured in other countries, such as China. We previously reported on this on our blog here. …

In the recent flurry of US Government activity related to Xinjiang, one thing is clear: trade compliance risks continue to increase for companies with supply chains that involve Xinjiang. These latest actions add to the expanding list of companies that face import bans, export bans, and sometimes both, in addition to broader measures under consideration in Congress. This blog post summarizes the past month’s developments. Companies with Xinjiang anywhere in their supply chains should be…

On June 8, 2021, the White House published a set of reports on the 100-day interagency reviews (“Reports”) conducted pursuant to Executive Order 14017 (“Supply Chain EO”), which assessed supply chain risks and vulnerabilities for several supply chains, including those relating to semiconductor manufacturing and advanced packaging, and made policy recommendations to address those risks. The Reports suggest that export controls on semiconductor-related equipment and technology can help protect the technological advantage of the United States in…

On June 8, 2021, the White House published a set of reports on the 100-day interagency reviews conducted pursuant to Executive Order 14017 “America’s Supply Chains” (“the Reports”). The Reports were accompanied by a White House Fact Sheet summarizing the key findings, expressing support for some of the policy recommendations, and announcing additional Biden Administration measures directed at strengthening the resilience of the country’s supply chains. Our prior blog post summarizing high-level key compliance-related aspects…

Last week’s post summarized the key findings from the reports and accompanying fact sheet published by the White House on Supply Chain resilience pursuant to Executive Order 14017 “America’s Supply Chains” (“the Reports”).  In this post, we dive deeper into the supply chain transparency and governance recommendations made with respect to regulations governing sourcing of critical minerals. This portion of the Reports outlined findings and recommendations pertinent to companies managing critical minerals supply chains, including…

On June 8, the White House published a set of reports on the 100-day interagency reviews conducted pursuant to Executive Order 14017 “America’s Supply Chains” (“the Reports”).  The Reports assessed supply chain risks and vulnerabilities related to the following four key supply chains and made policy recommendations to address those risks: semiconductor manufacturing and advanced packaging;large capacity batteries, including electric vehicle batteries;critical minerals and materials; andpharmaceuticals and advanced pharmaceutical ingredients. The Reports were accompanied by…

On April 21, the US Department of Agriculture (“USDA”) published a request for comments on supply chains for the production of agricultural commodities and food products under the America’s Supply Chains Executive Order (the “Supply Chain EO”) that President Biden signed on February 24, 2021. (See our blog post on the Supply Chain EO for more background.) Agricultural commodities and food products is one of the six industrial sectors the supply chains of which are subject to review pursuant…

On April 13, the US Department of Defense (“DOD”) published a request for comments on the strategic and critical materials supply chain under the America’s Supply Chains Executive Order (the “Supply Chain EO”) that President Biden signed on February 24, 2021. (See our blog post on the Supply Chain EO for more background.) Strategic and critical materials, which include rare earth elements and other minerals and metals used in laptops, cell phones, and other technologies,…