News & Analysis as of

Foreign Direct Product Rule

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

Foley Hoag LLP

Understanding BIS’s Affiliates Rule and Compliance Implications

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Key Takeaways - The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (the “IFR” or “Affiliates Rule”) that applies Export Administration Regulations (“EAR”) end user...more

Holland & Knight LLP

BIS Expands Impact of U.S. Export Controls with 50 Percent Rule

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The U.S. Department of Commerce Bureau of Industry and Security (BIS) published a much-anticipated interim final rule (IFR) on Sept. 30, 2025. The IFR makes foreign entities that are owned 50 percent or more, directly or...more

Latham & Watkins LLP

US Commerce Department Adopts Affiliates Rule Expanding Export Restrictions

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This measure significantly expands the scope of Entity List and Military End-User List restrictions, imposing heightened diligence obligations and complicating EAR compliance....more

Pillsbury - Global Trade & Sanctions Law

Commerce Department Issues “Affiliates Rule,” Extends Entity List Restrictions to Majority-Owned Foreign Entities

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a long-anticipated interim final rule (IFR) amending the Export Administration Regulations (EAR) to extend Entity List and...more

Orrick, Herrington & Sutcliffe LLP

BIS Expands End User Export Controls with 50% Rule

The U.S. Commerce Department has expanded export control sanctions by extending them to 50% or more-owned affiliates of restricted parties. This development has a particularly significant impact on China-related export...more

ArentFox Schiff

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

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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

Morrison & Foerster LLP

BIS Adopts 50% “Affiliates Rule”: Implications for Compliance and Enforcement

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an Interim Final Rule significantly expanding the scope of list‑based U.S. export controls (the “Affiliates Rule”)....more

Ropes & Gray LLP

U.S. Export Controls: BIS Adopts OFAC-Style 50 Percent “Affiliates” Rule

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On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced an Interim Final Rule (“IFR”) that aligns the Entity List and Military End User (“MEU”) List of the Export...more

Fenwick & West LLP

BIS Expands Entity List and MEU List Restrictions to Owned Entities with New ‘Affiliates Rule’

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On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule expanding restrictions on Entity List and Military End-User (MEU) List parties to automatically apply...more

American Conference Institute (ACI)

[Event] 7th Conference on China Trade Controls - November 6th - 7th, Arlington, VA

It is crucial for trade compliance teams to stay informed and stay agile as trade negotiations between the U.S. and China continue and new risks emerge. ACI's 7th Conference on China Trade Controls is the only trade...more

Baker Botts L.L.P.

AI Legal Watch: July 31

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As reported, on July 23, 2025, the White House released "Winning the AI Race: America's AI Action Plan," a strategy designed to secure U.S. leadership in artificial intelligence. This plan, which includes over 90 federal...more

Fenwick & West LLP

Trump Administration’s AI Action Plan Previews Changes to Export Controls and Enforcement

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On July 23, 2025, the White House unveiled “Winning the AI Race: America’s AI Action Plan,” which provides for federal policy actions the Trump Administration intends to take related to Artificial Intelligence (AI). The...more

American Conference Institute (ACI)

[Virtual Conference] EAR Compliance & Licensing Masterclass - July 14th - August 7th, 12:00 pm - 3:00 pm EDT

The Trump Administration is aiming to eliminate loopholes in the U.S. export controls system, expand the scope of the EAR, and ramp up enforcement. Get the insights you and your team need to strengthen your compliance program...more

Torres Trade Law, PLLC

InsightsCommerce Imposes Sweeping New Rule Restricting Exports of AI Chips

On January 13, 2025, the Department of Commerce Bureau of Industry and Security (BIS) announced new rules restricting the export of advanced artificial intelligence (AI) chips and certain closed AI model weights in an...more

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more

ArentFox Schiff

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

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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

Sheppard Mullin Richter & Hampton LLP

The Persistence of (High Bandwidth) Memory: Semiconductor Manufacturing Equipment and Korean Semiconductor Manufactures Face...

On December 2, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) issued a new set of regulations targeting semiconductors manufacturing equipment (SME) and high-bandwidth memory (HBM) chips. The updates...more

Morrison & Foerster LLP

In its Twilight, Biden Administration Adopts More Export Controls to Restrict China’s Ability to Produce Advanced Semiconductors

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Although the Trump transition is well underway, the Biden administration made news in the national security space by announcing significant new export restrictions on semiconductor equipment and technology destined for the...more

Troutman Pepper Locke

BIS Strengthens Export Controls on ‎China’s Advanced Technology Capabilities

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On December 2, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced two interim final rules (collectively, the “December 2024 Rules”) (“Foreign-Produced Direct Product Rule Additions, and...more

Baker Botts L.L.P.

China Bans Exports to U.S. of Critical Minerals Used in High Tech “Dual-Use” Materials

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On December 3, 2024, the Chinese Ministry of Commerce announced strict export restrictions on “dual-use” technologies. Dual-use technologies are those that are developed for civilian markets but also have military utility or...more

Pillsbury Winthrop Shaw Pittman LLP

China Issues New Export Control Regulations on Civil-Military Dual-Use Items

The new export control regulations consolidate existing dual-use items export control regulations and aim to regulate the export of goods, technologies and services that can be used for both civilian and military purposes. ...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - September 19, 2024

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The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...more

Troutman Pepper Locke

BIS Issues New FDP Restrictions on Goods Destined for Iran

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On April 24, 2024, President Biden signed into law the "Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2024, and for Other Purposes" Act. This law mandates that the United States...more

Fenwick & West LLP

Commerce Department Expands Export Jurisdiction for Foreign-Made Items to Iran: Foreign Direct Product Rule Update

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On July 24, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) announced amendments to the U.S. Export Administration Regulations (EAR), expanding the reach of U.S. export jurisdiction over certain...more

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