On November 18, 2020, the Department of Justice (DOJ) announced that a Chinese national and naturalized citizen of the United States was sentenced to 38 months in prison for travelling to China with unclassified military-related technical information. Wei Sun was employed as an electrical engineer with Raytheon Missiles and Defense for ten years. During this
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Export Controls, Sanctions and CFIUS
Departments of State and Commerce Announce Policy Changes to US Export Laws in Response to Hong Kong National Security Law
On June 30, 2020 at 11:00 PM Hong Kong time, the Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong Special Administrative Region (HK National Security Law) took effect. The HK National Security Law was adopted by the Standing Committee of the National People’s Congress of the People’s Republic…
Everybody’s Crying National Security, Just as Long as There’s Business First
The title of this article is based on a line in an old song, “Everybody’s Crying Mercy,” by Mose Allison. As modified, the couplet captures the cognitive dissonance that many are feeling as a result of the federal government’s conflicting approach to trade with Huawei Technologies Co. Ltd. (Huawei) and its non-United States affiliates. In…
New Year, New Voluntary Self-Disclosure Policy for Export Controls and Sanctions
Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations, something is wrong. He reasoned that every company is made up of human beings—and human beings make mistakes, so every company doing lots…
New Changes to the ITAR Focus on Unclassified Technical Data And the release of “Access Information”
As part of its years-long project to update and revise the International Traffic in Arms Regulations (ITAR) and better align them with the Export Control Regulations, the Department of State (DoS) recently amended the ITAR with an interim rule to address another group of amendments first proposed in June of 2015. The new rule defines…