OFAC issued the advisory to explain that a sham transaction designed to evade sanctions does not extinguish a sanctioned person’s interest in property. As a result, OFAC continues to impose blocking sanctions and prohibit...more
The FCC maintains a “Covered List” of communications equipment and services that have been determined to pose an unacceptable risk to the national security of the United States or the security and safety of U.S. persons. ...more
The trade relationship between the United States and China continues to evolve as both countries pursue their economic imperatives, industry autonomy, and geopolitical positioning. Each side is deploying a range of trade...more
3/27/2026
/ BIOSECURE Act ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Countermeasures ,
Economic Sanctions ,
Export Controls ,
Exports ,
Federal Acquisition Regulations (FAR) ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Ports ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trade Relations ,
US Trade Policies
Since March 1, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued multiple new measures relieving some of the sanctions on Venezuela as part of the ongoing thaw in the U.S....more
On February 11, 2026, Applied Materials, Inc. entered into a settlement agreement for a civil monetary penalty of over $252 million with the U.S. Department of Commerce, Bureau of Industry and Security (BIS) for 56 unlawful...more
3/3/2026
/ Bureau of Industry and Security (BIS) ,
China ,
Civil Monetary Penalty ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Direct Product Rule ,
Semiconductors ,
Settlement Agreements ,
U.S. Commerce Department
The United States has officially lifted its arms embargo, including certain highly restrictive export controls, with respect to Cambodia, reflecting a recalibration of regional policy and cooperation between the countries on...more
2/10/2026
/ Arms Embargo ,
Bureau of Industry and Security (BIS) ,
Cambodia ,
CFIUS ,
Defense Sector ,
Embargo ,
Export Administration Regulations (EAR) ,
Export Controls ,
Federal Contractors ,
Foreign Investment ,
International Trade ,
ITAR ,
National Security ,
Significant Transnational Criminal Organization ,
U.S. Commerce Department
On January 21, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (IFR) relaxing export controls on certain commercial UAVs to certain allied and partner countries....more
2/3/2026
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
Drones ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
FCC ,
Interim Final Rules (IFR) ,
International Trade ,
U.S. Commerce Department ,
Unmanned Aircraft Systems
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil” (General License), on January 29, 2026, permitting U.S....more
On January 15, 2026, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published an amendment to the Export Administration Regulations (EAR) that is designed to allow for increased exports of NVIDIA H200,...more
1/22/2026
/ Amended Regulation ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
IaaS ,
Infrastructure ,
International Trade ,
Macau ,
National Security ,
Trade Relations ,
U.S. Commerce Department
Last week, the President signed the National Defense Authorization Act for Fiscal Year 2026 (NDAA) into law, enacting a wide range of statutory directives that will shape U.S. defense, trade, and national security policy in...more
12/26/2025
/ CFIUS ,
Cross-Border Transactions ,
Defense Sector ,
Department of Defense (DOD) ,
Export Controls ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Funding ,
Foreign Investment ,
International Trade ,
ITAR ,
National Security ,
NDAA ,
New Legislation ,
Procurement Guidelines ,
Technology Sector
The final draft of the FY 2026 National Defense Authorization Act (NDAA) includes the proposed BIOSECURE Act (the Act), which would place restrictions on dealings with certain “biotechnology companies of concern” (BCOCs) by...more
12/12/2025
/ BIOSECURE Act ,
Biotechnology ,
China ,
Department of Defense (DOD) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Funding ,
Federal Grants ,
Federal Loans ,
National Security ,
NDAA ,
Proposed Legislation ,
Supply Chain
On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule expanding restrictions on Entity List and Military End-User (MEU) List parties to automatically apply...more
9/30/2025
/ Affiliates ,
Bureau of Industry and Security (BIS) ,
Due Diligence ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Foreign Entities ,
International Trade ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
U.S. Commerce Department
The Department of Justice (DOJ) has announced a new Trade Fraud Task Force with broad civil and criminal authority to enforce tariffs and customs regulations. The initiative, announced on August 29, 2025, consolidates...more
9/23/2025
/ Customs ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Enforcement Authority ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Fraud ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Tariffs ,
Trump Administration ,
U.S. Customs ,
Whistleblowers
On August 28, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule relaxing export controls on Syria in response to the June 30, 2025 Executive Order (EO) 14312 “Providing for the...more
9/2/2025
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Syria ,
U.S. Commerce Department ,
US Trade Policies
The Trump administration has announced multiple new developments in U.S. tariff policy since our April update. The administration is using several different tools to implement tariffs, including § 232 and 301 investigations...more
8/14/2025
/ Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Investigations ,
Section 232 ,
Section 301 ,
Tariffs ,
Trade Act of 1974 ,
Trump Administration ,
US Trade Policies ,
USTR
On August 6, 2025, the U.S. Department of the Treasury released its Committee on Foreign Investment in the United States (CFIUS or the Committee) 2024 Annual Report to Congress. The report includes anonymized statistics and...more
On July 23, 2025, the White House unveiled “Winning the AI Race: America’s AI Action Plan,” which provides for federal policy actions the Trump Administration intends to take related to Artificial Intelligence (AI). The...more
7/25/2025
/ Artificial Intelligence ,
China ,
Enforcement ,
Export Controls ,
Foreign Direct Product Rule ,
Infrastructure ,
International Trade ,
National Security ,
Regulatory Requirements ,
Semiconductors ,
Trump Administration ,
U.S. Commerce Department
On July 11, 2025, the Trump administration published an order forcing Suirui International Co., Limited—a Hong Kong company that is majority owned by Suirui Group Co., Ltd., a People’s Republic of China company—to unwind its...more
7/16/2025
/ Acquisitions ,
CFIUS ,
China ,
Critical Infrastructure Sectors ,
Divestiture ,
Foreign Corporations ,
Foreign Investment ,
Hong Kong ,
Investment ,
National Security ,
Trump Administration
On June 30, 2025, the White House issued Executive Order 14312, Providing for the Revocation of Syria Sanctions (the Syria EO), terminating U.S. comprehensive sanctions on Syria effective July 1, 2025. ...more
7/8/2025
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
State Sponsors of Terrorism ,
Syria ,
U.S. Treasury
The U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) administers a survey every five years to collect information from U.S. persons that hold, directly or indirectly, at least 10% of the voting interest in a...more
Section 232 investigations determine whether the targeted U.S. imports threaten to impair U.S. national security. At the conclusion of a Section 232 investigation (which can last for up to 270 days), the President must...more
4/22/2025
/ Bureau of Industry and Security (BIS) ,
Executive Orders ,
Government Investigations ,
Imports ,
National Security ,
Pharmaceutical Industry ,
Section 232 ,
Semiconductors ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department
On April 2, 2025, President Donald Trump issued an executive order (EO) on tariffs called "Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States...more
4/8/2025
/ Canada ,
China ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Supply Chain ,
Tariffs ,
Trump Administration ,
US Trade Policies