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ARTICLE · 18 MARCH 2021

Sanctions/Export Controls Trends In 2021

Foley Hoag LLP
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The recent change in administrations has generated much discussion about what to expect in the worlds of export controls and sanctions in 2021. In general, we expect many of the same priorities...

GlobalInternational Law
Luciano Racco
Luciano Racco
Shrutih Tewarie
Shrutih Tewarie
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This is the second in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed SEC enforcement. Up next, anti-corruption trends.

The recent change in administrations has generated much discussion about what to expect in the worlds of export controls and sanctions in 2021.  In general, we expect many of the same priorities from 2020, including a focus on China and Russia, to continue in 2021, but with a more measured and multi-lateral approach.

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China. The Trump administration continued to take numerous significant export controls and sanctions-related measures against China in 2020.  On April 28, 2020, the Department of Commerce's Bureau of Industry and Security ("BIS") issued a new rule under the Export Administration Regulations ("EAR"), expanding the export, re-export, and transfer controls related to military end use and

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