The Bureau of Industry and Security announced March 10 that it will extend for another 45 days, through May 15, a temporary general license authorizing certain exports to Huawei Technologies Co. Ltd. and 114 of its non-U.S. affiliates on the Entity List. BIS is also seeking input by March 25 on future extensions of a TGL under the Export Administration Regulations.

The TGL covers certain activities necessary for the continued operations of existing networks and equipment as well as the support of existing mobile services, including cybersecurity research critical to maintaining the integrity and reliability of existing and fully operational networks and equipment. Exporters, reexporters, and transferors that qualify to use the TGL must maintain certifications and other records regarding their use of it that must be made available to BIS upon request. In addition, any exports, reexports, or in-country transfers of items subject to the EAR to these entities that are not explicitly authorized by this TGL continue to require a license and license applications will continue to be reviewed under a presumption of denial.

Meanwhile, interested parties may submit input by March 25 to assist the U.S. government in evaluating whether the TGL should continue to be extended and whether any other changes may be warranted to the TGL, as well as to identify any alternative authorization or other regulatory provisions that may more effectively address what is being authorized under the TGL.

Given the extent of Huawei’s supply chain in the U.S., companies should be screening or re-screening their customer, vendor, and other third-party data against the list of Huawei affiliates to identify any potential ongoing or pending transactions with these parties and set up appropriate controls to ensure compliance with U.S. export control laws. Violations can result in significant financial penalties, denial of export privileges, and reputational damage.

ST&R’s export controls and sanctions team is positioned to support companies in their screening efforts and help them mitigate the risks of doing business in this ever-evolving geopolitical climate. Please contact export attorney Kristine Pirnia for more information.

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