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ARTICLE · 19 JULY 2024

BIS Issues New Guidance Targeting Diversion Risks

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On July 10, 2024, the US Department of Commerce's Bureau of Industry and Security (BIS) published new guidance describing several of the tools that BIS uses now to directly notify...

United StatesInternational Law
Quentin Johnson
Quentin Johnson
Wendy Wysong
Wendy Wysong
Jack Hayes
Jack Hayes
Meredith Rathbone
Meredith Rathbone

On July 10, 2024, the US Department of Commerce's Bureau of Industry and Security (BIS) published new guidance describing several of the tools that BIS uses now to directly notify companies and universities about the potential diversion of items in violation of the Export Administration Regulations (EAR). As discussed in more detail below, industry and academia should be aware that a notice from BIS may place additional due diligence requirements or restrictions on the recipient. Below is a brief summary of BIS's methods of notifying companies and universities and BIS's expectations for recipients of those notices.

"Supplier List" Letters

  • What should recipients expect?

A "supplier list" letter identifies parties of diversion concern. A company or university may receive a "supplier list" letter regardless of whether or not it has previously transacted with those parties. Beginning in March 2024, BIS issued "supplier list" letters containing a list of

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