News & Analysis as of

Bureau of Industry and Security (BIS) National Security

Fenwick & West LLP

Regulatory Impact of Arms Embargo Country Designations

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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

Morrison & Foerster LLP

Managing Export Control Risks in the AI Chip Ecosystem

Recent actions by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Department of Justice (DOJ) highlight how enforcement risk extends beyond manufacturers and exporters to include...more

Pillsbury Winthrop Shaw Pittman LLP

Trump Administration Takes Several Trade Actions Targeting Advanced AI Semiconductors While Deferring Broader Tariff Actions on...

In recent weeks, the Trump administration has taken several actions to implement its policy toward the export of advanced AI commodities to China. These include the Department of Commerce (Commerce) Bureau of Industry’s (BIS)...more

Troutman Pepper Locke

The Risk of Voluntary Self Disclosure: Takeaways From the Exyte BIS Settlement

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The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently entered into a settlement agreement with German entity Exyte Management GmbH (Exyte) due to in‑country transfers by distributors of one of its...more

Hogan Lovells

BIS revises licensing requirements for commercial UAVs

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a new interim final rule on January 20, 2026 that makes two changes in an attempt to ease licensing requirements on certain commercial UAVs. ...more

Cozen O'Connor

Recent Updates to U.S. Export Control Regulations Further Ease UAV Restrictions for U.S. Exporters

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On January 21, 2026, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR) that results in an easing of export restrictions for certain unmanned aerial vehicles (UAVs) and...more

ArentFox Schiff

BIS Relaxes Drone Export Controls to Bolster Defense Industrial Base

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In a January 20 interim final rule, the Bureau of Industry and Security (BIS) eased restrictions on the export, reexport, and transfer (in-country) of certain types of unmanned aerial vehicles (UAVs) to lower risk...more

White & Case LLP

President Trump Orders Narrowly Targeted 25% Section 232 Tariff On Certain Advanced Semiconductor Articles

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On January 14, 2026, President Trump issued a Presidential Proclamation adopting actions under the Section 232 investigation of advanced semiconductors, semiconductor manufacturing equipment, and derivative products....more

Fenwick & West LLP

BIS Opens the Door to Increasing AI Chip Exports to China

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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

The Volkov Law Group

Trade Enforcement: A Look Back (Part I of II)

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Typically, I enjoy the New Year (notwithstanding Larry David’s rule of no New Year wishes past 15 days of the New Year). It is important to look back, assess and identify trends; after all, what better marker than annual...more

White & Case LLP

President Trump Orders Critical Minerals Trade Negotiations In Section 232 Action

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On January 14, 2026, President Trump issued a Presidential Proclamation implementing Section 232 measures to address national security risks associated with imports of processed critical minerals and their derivative products...more

Morgan Lewis

BIS Revises Export Review Policy for Advanced AI Chips Destined for China and Macau

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The licensing review policy has shifted from a presumption of denial to case-by-case licensing with strict conditions. This new export policy occurred in parallel with an increase in US tariffs on semiconductors with the same...more

Troutman Pepper Locke

From Chips to Minerals: New Section 232 Tariff Actions Target Semiconductors and Critical Minerals

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On January 14, President Trump issued two proclamations under Section 232 of the Trade Expansion Act of 1962 (Section 232) addressing national security risks associated with imports of processed critical minerals and...more

ArentFox Schiff

Top Five Export Controls and Sanctions Areas to Watch in 2026

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Last year saw a number of significant developments in US export controls and sanctions....more

Torres Trade Law, PLLC

The Current Landscape of Section 232 Tariff Actions

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The second Trump administration has focused heavily on trade regulation, including initiating several investigations under Section 232 of the Trade Expansion Act of 1962 (“Section 232 investigations”). Section 232...more

Husch Blackwell LLP

BIS to Open Window for Additional Products Subject to Section 232 Duties on Auto Parts on January 1, 2026

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On December 16, 2025 the Bureau of Industry and Security (BIS) announced that it will provide an opportunity for interested parties to submit requests to add additional products to the list of auto parts that are subject to...more

Foley & Lardner LLP

What Every Multinational Should Know About . . . U.S. Export Controls & Economic Sanctions

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Both the Biden and the Trump administrations have been expanding U.S. export controls (particularly regarding China) and promulgating new and comprehensive economic sanctions. To reflect the increasing risks of these...more

Snell & Wilmer

Aircraft Tariffs Take Flight? What Importers and Transactional Counsel Should Know About the New Section 232 Investigation

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The Bureau of Industry and Security (BIS) at the U.S. Department of Commerce launched a Section 232 investigation into the national security implications of aviation imports. This development did not make headlines due to the...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - December 2025 - Section 232 Steel & Aluminum Derivative Products Inclusion Process Expands...

On February 10, 2025, the President issued Presidential Proclamations Under Section 232 of the U.S. Code adjusting imports of steel and aluminum into the United States. These Proclamations provided an expanded listing of...more

Morgan Lewis

US Government Reopens: What to Know

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With the federal government reopening, US agencies are resuming operations while beginning to tackle the challenges created by the shutdown. This LawFlash provides a rundown of how government bodies are addressing these...more

Wiley Rein LLP

United States and China Negotiate One-Year Trade Deal

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On November 1, 2025, the White House reached a framework deal with the People’s Republic of China (PRC) outlining resolutions to several areas of dispute in the ongoing U.S.-PRC trade conflict. The agreement marks the...more

Morgan Lewis

Dutch and German Regulators Scrutinize Nexperia Transactions Amid US Export Pressures

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Dutch and German authorities are taking action in the semiconductor sector, underscoring the growing need to address supply-chain concerns. US approaches to export controls and foreign investment screening appear to be having...more

Skadden, Arps, Slate, Meagher & Flom LLP

BIS Suspends Affiliates Rule for One Year as Part of the US-China Trade Deal

On November 10, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule, announcing a one-year suspension (the Suspension) of its interim final rule, “Expansion of End-User Controls to...more

Husch Blackwell LLP

BIS Suspends “Affiliates Rule” for One Year Following U.S. Agreement with China

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The U.S. Commerce Department’s Bureau of Industry and Security (BIS) has issued a final rule which will suspend BIS’s recently enacted Affiliates Rule effective as of November 10, 2025 and continuing through November 9, 2026....more

Davis Wright Tremaine LLP

Section 232 in the Spotlight: The Current State of National Security Tariffs

With the fate of many of President Trump's signature tariffs targeting foreign countries under the International Emergency Economic Powers Act of 1977 (IEEPA) in some doubt, his administration has relied more heavily on...more

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