Megan Barnhill

Megan Barnhill

ArentFox Schiff

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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

11/18/2025  /  China , Customs and Border Protection , Department of Justice (DOJ) , Export Controls , False Claims Act (FCA) , International Emergency Economic Powers Act (IEEPA) , Section 232 , Section 301 , Supply Chain , Tariffs

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

10/20/2025  /  Bureau of Industry and Security (BIS) , Customs and Border Protection , Forced Labor , International Trade , Public Comment , Section 232 , Supply Chain , Tariffs , Uyghur Forced Labor Prevention Act (UFLPA) , Withhold Release Orders (WROs)

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

10/2/2025  /  Bureau of Industry and Security (BIS) , Due Diligence , Economic Sanctions , Entity List , Export Administration Regulations (EAR) , Export Controls , Foreign Direct Product Rule , Office of Foreign Assets Control (OFAC) , Risk Management , Supply Chain

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

9/16/2025  /  Biden Administration , Bureau of Industry and Security (BIS) , China , Export Administration Regulations (EAR) , Export Controls , Foreign Investment , International Trade , Semiconductors , Supply Chain , U.S. Commerce Department
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