On Thanksgiving Eve, Wednesday, November 27, the U.S. Department of Commerce released a proposed rule that intends to provide the U.S. Secretary of Commerce the authority to block, require the unwinding of or require mitigating modifications to information and communications technology or services (ICTS) transactions involving “foreign adversaries” if the Commerce Secretary determines that such transactions threaten U.S. critical infrastructure, the U.S. digital economy or U.S. national security. While this proposed rule is not yet final, it does threaten to complicate the holiday season for many beleaguered data security and trade compliance professionals as they scramble to compile and submit comments to the Department of Commerce before the proposed rule’s comment submission deadline expires on Friday, December 27, 2019.
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Husch Blackwell’s International Trade & Supply Chain team counsels businesses on navigating the intricate network of customs, export controls and other regulations that affect the movement of goods worldwide