The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule on September 30, 2025, rescinding the 2024 interim final rule (“Firearms IFR”) under the Export Administration Regulations (“EAR”)...more
The U.S. Department of State (“State”) announced an update to its miliary drone export review policy on September 15, 2025, pursuant to which advanced unmanned aerial systems (“UAS”) will be subject to an export control...more
Welcome to this month’s issue of the BR International Trade Report, Blank Rome’s monthly digital newsletter highlighting international trade, cross-border investment, and geopolitical risk issues impacting businesses...more
9/12/2025
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SCOTUS ,
Section 232 ,
Tariffs ,
US Trade Policies
On August 16, 2024, the U.S. Department of State (“State”) announced a broad exemption from export licensing requirements for most defense trade between and among “authorized users” in the United States, Australia, and the...more
The U.S. Department of the Treasury (“Treasury”) recently issued a Notice of Proposed Rulemaking (“NPRM”), setting the stage for regulation of certain U.S. outbound investment in China and China-linked companies. This NPRM is...more
President Biden last month signed into law H.R. 815 (“National Security Supplemental” or “NSS”). The NSS—a package of national security and foreign aid appropriations, including for efforts in Israel, Ukraine, and the...more
The U.S. Department of the Treasury (“Treasury”) recently issued a Notice of Proposed Rulemaking (“NPRM”) that would enhance and expand authorities of the Committee on Foreign Investment in the United States (“CFIUS” or “the...more
Introduction The United States spends hundreds of billions of dollars annually on government contracts, grants, and other forms of federal assistance. Although most entities that receive these awards are good business...more
On July 19, 2023, Rep. Michael McCaul (R-TX), chair of the House of Representatives Foreign Affairs Committee, introduced a bill to ease trade restrictions among parties to the AUKUS agreement—a trilateral security...more
On June 1, 2023, the U.S. Department of State, Directorate of Defense Trade Controls (“DDTC”) published under the International Traffic in Arms Regulations (“ITAR”) updated Open General License (“OGL”) Nos. 1 & 2, extending a...more
Effective January 1, 2023, the certification process for veteran-owned small businesses (“VOSBs”) and service-disabled veteran-owned small businesses (“SDVOSBs”) will be transferred from the Department of Veterans Affairs...more
The Uyghur Forced Labor Prevention Act (“UFLPA” or “Act”), which took effect last month, ushers in a new era of supply chain diligence for importers. The Act creates a rebuttable presumption that any goods produced in whole...more