New Restrictions on Exports to Russia: US Technology Embedded in Products Made Overseas

On 16 March, Sunstein LLP published an article saying that the foreign direct product (FDP) rule represents an ambitious attempt by the United States to expand its export controls to goods manufactured in foreign countries.  This rule was promulgated by the Commerce Department’s Bureau of Industry and Security (BIS).  BIS regulates the export of sensitive items that are not munitions, the export of which is subject to State Department control under the International Traffic in Arms (ITAR) regulations.  The FDP rule subjects to US export regulations products made overseas that are the direct product of technology or software of US origin; or that are the direct product of a plant, or major component of a plant, that is itself a direct product of US-origin technology or software.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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