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The Volkov Law Group

Episode 396 — Commerce Department Levies Second Largest Fine Against Applied Materials for Illegal Exports to China

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The Commerce Department’s Bureau of Industry and Security (BIS) has sent an unmistakable message to the semiconductor industry: creative interpretations of the Export Administration Regulations (EAR) will not shield companies...more

Fenwick & West LLP

Applied Materials Pays $252 Million Penalty for Export Violations Involving SMIC

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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

ArentFox Schiff

BIS Imposes Record Penalty on Applied Materials, Rejects Customs’ Substantial Transformation Test, but Offers No Clear Standard...

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On February 11, the US Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement agreement and $252 million civil penalty against California-based Applied Materials Inc. and its subsidiary Applied...more

The Volkov Law Group

Commerce Department Levies Second Largest Fine Against Applied Materials for Illegal Exports to China

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The Commerce Department’s Bureau of Industry and Security (BIS) has sent an unmistakable message to the semiconductor industry: creative interpretations of the Export Administration Regulations (EAR) will not shield companies...more

Bass, Berry & Sims PLC

Export Enforcement Update: Huge Penalty Imposed for Semiconductor Re-Exports to China

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On February 11, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Applied Materials, Inc. (AMAT) and Applied Materials Korea, Ltd. (AMK) resolving allegations that the...more

The Volkov Law Group

UFLPA Enforcement: When a “Red Light” Turns Yellow

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The Uyghur Forced Labor Prevention Act (UFLPA) was designed to be one of the toughest trade enforcement statutes ever enacted by Congress....more

Bass, Berry & Sims PLC

Export Enforcement Update: EAR99 “In-Country” Transfers Lead to Penalty

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On January 7, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Order resolving allegations that Exyte Management GmbH (Exyte), a Germany-based company, committed 13 violations of the Export...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

The Volkov Law Group

BIS Imposes $1.5 Million Penalty on Exyte for Unlicensed In-Country Transfers to SMIC

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On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Order resolving an administrative enforcement action against Exyte Management GmbH, a Germany-based company headquartered...more

American Conference Institute (ACI)

[Event] 3rd Advanced Forum on Global Export Controls - February 24th - 25th, Arlington, VA

If you are a trade and legal compliance decision-maker, where can you go to learn, expand your export controls brain trust, and strengthen your strategy? At ACI’s Advanced Forum on Global Export Controls, you’ll connect...more

Torres Trade Law, PLLC

Export Controls & Sanctions: 2025 Year-End Review

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As 2025 comes to an end, one theme defines the global compliance landscape: volatility. Over the past twelve months, sanctions and export control regimes have shifted quickly as the second Trump administration reshaped...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - December 2025 - Overview of BIS’s Interim Final Rules, Export Controls for Advanced Computing,...

On November 10, 2025, the U.S. Bureau of Industry and Security (“BIS”) delayed the effective date of its new Affiliates Rule for a one-year period, until November 9, 2026, after U.S. and China trade talks. The Affiliates...more

Jones Day

BIS Suspends Affiliates Rule, China Pauses Rare Earth Export Controls

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Effective November 10, 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") formally suspended enforcement of its newly announced Affiliates Rule for one year following a U.S.–China framework trade...more

Pillsbury Winthrop Shaw Pittman LLP

China Suspends Export Controls on Certain Critical Minerals and Related Items

On October 9, 2025, China’s Ministry of Commerce (MOFCOM and General Administration of Customs (GAC) published a set of announcements (Nos. 55 to 58 and 61, 62) with a series of export control measures. These include export...more

Fenwick & West LLP

BIS Suspends the Affiliates Rule, Lifting Restrictions on Restricted Party Affiliates

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On November 10, 2025, the United States Department of Commerce, Bureau of Industry and Security (BIS) announced a one-year suspension of the “Affiliates Rule,” which imposed U.S. export control restrictions on entities 50...more

Blank Rome LLP

BIS Suspends "Affiliates Rule" for One Year, Effective November 10

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On November 10, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule delaying enforcement of the “Affiliates Rule” that BIS issued on September 29. The one-year suspension ends...more

Morrison & Foerster LLP

United States and China Reach Trade Agreement: Takeaways for Export and Supply Chain Controls

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Following a bilateral meeting in Busan, South Korea, on October 30, 2025, between President Donald Trump and President Xi Jinping, the United States and China announced an agreement (the “Agreement”) intended to ease...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

Lowenstein Sandler LLP

One-Year Suspension of End-User Controls for Affiliates of Listed Entities

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On November 12, 2025, the Bureau of Industry and Security (BIS) at the Department of Commerce published a one-year suspension of the “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities” rule (the...more

Vinson & Elkins LLP

Growing Trade Compliance Hurdles: BIS Adopts the 50% Rule for Entity List and MEU List Entities (UPDATED)

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UPDATE - On November 10, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its final rule staying the new Affiliates Rule, which will make any unlisted foreign entity owned, directly or...more

Wilson Sonsini Goodrich & Rosati

BIS Formally Suspends New “Affiliates Rule” for One Year

On November 11, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) formally published a one year suspension of the “Affiliates Rule,” previously announced by Treasury Secretary Scott Bessent, in the...more

ArentFox Schiff

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

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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

Kelley Drye & Warren LLP

White House Issues 1-Year Suspension for BIS 50% Rule Beginning November 10th

On November 1, 2025, the White House formally announced in a fact sheet that the United States will suspend the Bureau of Industry and Security’s 50% rule, known as the BIS 50% Affiliates Rule, for one year starting Nov. 10,...more

Bass, Berry & Sims PLC

UPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-China

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On October 30, U.S. Treasury Secretary Scott Bessent announced that the U.S. Department of Commerce, Bureau of Industry and Security (BIS) will delay the implementation of the recently announced BIS Affiliates Rule for one...more

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