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As the (Customs and Trade) World Turns: November 2025

Welcome to the November 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Was It a Bird, Was It a Plane? No, It Was the BIS Affiliates Rule!

It’s hard not to experience whiplash with export controls recently. A little over a month ago, the Bureau of Industry and Security (BIS) announced the new Affiliates Rule, which took effect immediately on September 29....more

As the (Customs and Trade) World Turns: October 2025

Welcome to the October 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

BIS Adds New FAQs to Clarify Affiliates Rule - Our Top Takeaways

The Bureau of Industry and Security (BIS) updated its Entity List FAQs, providing some additional guidance about the “Affiliates Rule” that came into effect on September 29....more

BIS Adopts 50% ‘Affiliates’ Rule Across Entity List and Other End-User Based Export Controls

On September 29, the Bureau of Industry and Security (BIS) issued an interim final rule that significantly expands end user controls under the Export Administration Regulations (EAR) by extending restrictions to foreign...more

As the (Customs and Trade) World Turns: September 2025

Welcome to the September 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

BIS Revokes VEU Authorizations for Foreign-Owned Chip Factories in China

The affected facilities, which are owned by companies based in South Korea and Taiwan, will have to contend with licensing requirements in order to receive exports, re-exports, and transfers of controlled items from their...more

As the (Customs and Trade) World Turns: August 2025

Welcome to the August 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

As the (Customs and Trade) World Turns: July 2025

Welcome to the July 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Taking Stock – Summary of BIS Actions From Fall 2024, and Peek at What Is Next Under the Trump Administration

President Trump’s first months in office have been busy, but, in the export control world, we have been grateful for a brief respite from the mind-bending, hundreds-of-pages-long, industry-changing rules that the US...more

Navigating the Complexities of Forced Labor Laws: ArentFox Schiff’s 2025 Guide for Global Businesses

Navigating the Complexities of Forced Labor Laws - Last year, ArentFox Schiff’s (AFS) Forced Labor Enforcement Task Force published its first annual report to help multinational companies navigate the complexities of forced...more

As the (Customs and Trade) World Turns: January 2025

Welcome to the January 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

The Parting Blow – Biden Administration Issues Sweeping Export Controls on AI Models and Advanced Chips

The US Department of Commerce’s Bureau of Industry and Security (BIS) introduced its long-anticipated (some would say dreaded) Framework for Artificial Intelligence Diffusion (the AI Diffusion Rule) on January 15. Highlights...more

OFAC Relaxes Sanctions Against Post-Assad Syria – For Now

The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more

As the (Customs and Trade) World Turns: October 2024

Welcome to the October 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

As the (Customs and Trade) World Turns: September 2024

Welcome to the September 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Does the Proposed New ITAR Definition of ‘Defense Services’ Catch More Than it Releases in the Foreign Intelligence Area?

On July 29, the Directorate of Defense Trade Controls (DDTC) of the US Department of State proposed a new definition of the term “defense service.” The International Traffic in Arms Regulations (ITAR) imposes a license...more

Footnote Frenzy: Charting Out Commerce’s Proposed Expanded US Person and End Use Export Controls and Facial Recognition Controls

On July 29, the US government proposed big changes to rules about supporting or exporting to foreign military, intelligence, and security entities. The US Department of Commerce’s Bureau of Industry and Security (BIS) is...more

As the (Customs and Trade) World Turns: July 2024

Welcome to the July 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

As the (Customs and Trade) World Turns: June 2024

Welcome to the June 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

US Government Throws “Kitchen Sink” Export Controls at Russia, Plus Sweeping EAR99 Software Controls, and IT and Software Services...

Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more

BIS Authorizes Medical Device Exports to Russia, Belarus, and Occupied Ukraine (With Strings Attached)

License Exception MED, published by the US Department of Commerce’s Bureau of Industry and Security (BIS) on April 25, authorizes the export, reexport, or in-country transfer of EAR99 “medical devices” to non-military...more

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