BIS Issues Final Rule on China Exports
Client Alert | 1 min read | 06.18.07
In publishing its long-awaited rule imposing controls on exports to the PRC, BIS has imposed controls where the exporter "knows" of a military end use for 31 categories (down from 47) of items on the Commerce Control List, and created a new authorization for some exports to China that would require a license unless destined to Validated End Users ("VEUs"). In response to extensive public comments, BIS has modified the standard for evaluating "military end use," raised the dollar value of transactions requiring a PRC "End User Statement" (from $5,000 to $50,000), and set out the specific requirements for VEU status, including the specific information required to support an application and the creation of a new inter-agency "End User Review Committee" (including State, Defense, Energy, and others) which must unanimously approve all applications for VEU status. BIS has heralded the VEU, or "trusted customer," approach as a model for the future of export controls in an increasingly list-based compliance environment; this future will depend on the degree of practical usefulness of the VEU model as an alternative to traditional export licenses. The text of the Final Rule is available at http://www.bis.doc.gov/News/2007/Rule%20text.pdf.
Contacts
Insights
Client Alert | 2 min read | 05.29.26
California Assembly Passes AB 1776, Sending Major Antitrust Bill to the Senate
California’s COMPETE Act (AB 1776) narrowly passed the California State Assembly by three votes on Wednesday and now moves to the California State Senate. The bill — introduced in March by Assembly Majority Leader Cecilia Aguiar-Curry — is modeled closely on draft legislation recommended by the California Law Revision Commission in September. AB 1776 would not only significantly expand potential liability for single-firm conduct and monopolization but, based on recent amendments, would also explicitly decouple California antitrust analysis from certain federal standards. Crowell & Moring is representing the California Chamber of Commerce (CalChamber) in monitoring, analyzing, and responding to AB 1776.
Client Alert | 5 min read | 05.29.26
Clover Insurance v. HHS: S.D. of Georgia Holds 20 Star Ratings Measures Unlawful
Client Alert | 3 min read | 05.29.26
Client Alert | 3 min read | 05.28.26

