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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On October 27, 2023, the U.S. Department of Commerce <a href="https://www.bis.doc.gov/index.php/documents/policy-guidance/3374-2023-10-27-bis-faqs-firearms-pause-and-review/file" target="_blank" rel="noreferrer noopener">announced an immediate pause</a> on the issuance of new export licenses for certain firearms, related components and ammunition for a period of approximately 90 days. This pause applies globally to all non-governmental end users with some exceptions, notably for Ukraine, Israel and countries in Country Group A:1 (Wassenaar Arrangement Participating States). During this pause, the department will conduct a review to reassess current firearm export control policies with a focus on U.S. national security and foreign policy interests. The aim is to mitigate the risk of these firearms being misused in ways that could destabilize regions, violate human rights or fuel criminal activities.
The pause specifically targets items controlled under four Export Control Classification Numbers (ECCNs): ECCN 0A501, ECCN 0A502, ECCN 0A504 and ECCN 0A505. These items, when intended for non-governmental end users, will be affected by the pause unless they are destined for Ukraine, Israel or a country in Country Group A:1. Items being exported to these exceptions will continue to be reviewed for license applications, along with exports to any governmental end users worldwide.
During this period, exporters can still submit their license applications, but those subject to the pause will be placed on &ldquo;Hold Without Action&rdquo; (HWA) and will not be processed until the pause ends. Licenses that have already been issued prior to the pause remain valid and unaffected. However, it should be noted that the Bureau of Industry and Security (BIS) retains the authority to modify, suspend or revoke these licenses if necessary. BIS will notify exporters when the pause is over. Importantly, the License Exception for Limited Value Shipments is still available for parts and components controlled by ECCNs subject to the pause. 
This pause and review signifies a pivotal moment for the firearm export industry and may herald new regulatory landscapes in the near future. Companies and individuals involved in these exports should closely monitor any announcements from the department and BIS and may need to adjust their strategies accordingly.

BIS Halts New Licenses for Firearm Exports

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