As ECM prepared to go to press, the Commerce Department’s Bureau of Industry and Security (“BIS”) had a “Hold Without Action (HWA)” control on license applications. Occasionally, BIS will put specific sectors, products or license applications to certain destinations under a HWA in response to a particular development such as a new regulation or license exception. This time, however, there was no apparent announcement in the Federal Register or on the BIS website about the HWA and its scope. The ...
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