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General Licenses Export Administration Regulations (EAR) Exports

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

DLA Piper

Expansion of end-user controls to cover affiliates: BIS adopts 50 percent ownership rule for Entity List, Military End User List,...

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On September 30, 2025, the Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the Export Administration Regulations (EAR) to expand end-user controls and address diversion risks associated...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

Morgan Lewis

BIS Adopts ‘50% Rule’: Key Takeaways for Trade Compliance

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The Affiliates Rule automatically extends the US Department of Commerce’s Entity List and Military End-User (MEU) List to entities owned 50% or more by entities on either list. On September 29, 2025, the US Department of...more

Fenwick & West LLP

BIS Issues Rule Relaxing Export Controls on Syria, Authorizing EAR99 Items, and Expanding License Exceptions

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On August 28, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule relaxing export controls on Syria in response to the June 30, 2025 Executive Order (EO) 14312 “Providing for the...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - January 29, 2025

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In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert summarizes...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024 #2

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In its continuing response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic...more

Faegre Drinker Biddle & Reath LLP

Additional Export Restrictions to Russia and Belarus: BIS Announces Additional Export Sanctions Against Russia and Belarus and...

On June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced several significant additional export control restrictions and related actions against Russia as a response to continued...more

Foley Hoag LLP

BIS Introduces New License Exception for Export of Medical Devices to Russia, Belarus, and Occupied Regions of Ukraine

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License Exception MED - On April 25, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a final rule for a new license exception for “medical devices” under § 740.23 of the EAR (“License...more

BakerHostetler

Current State of U.S. Export Controls in Response to the Russian Federation’s Invasion of Ukraine - March 2024

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes the key export restrictions...more

Skadden, Arps, Slate, Meagher & Flom LLP

BIS Publishes Revisions to Export Administration Regulations, Loosening Restrictions on Certain Cameras and Imposing Controls on...

On February 23, 2024, the Department of Commerce Bureau of Industry and Security (BIS) published revisions to the Export Administration Regulations (EAR), loosening restrictions on the export of certain cameras, optical...more

BakerHostetler

Current State of U.S. Export Controls in Response to the Russian Federation’s Invasion of Ukraine - February 2024

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes the key export restrictions...more

Fenwick & West LLP

BIS Publishes New FAQs Related to Updated Advanced Computing/Supercomputing Rules

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The Commerce Department’s Bureau of Industry and Security (BIS) has published new FAQs that offer further guidance on two interim final rules that went into effect in November 2023. hese rules, for which the BIS is...more

Wiley Rein LLP

BIS Strengthens Export Controls Targeting China’s Acquisition of Semiconductor Equipment, Advanced Computing Items, and...

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For the second year running, and in what may prove to be a regular process, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has significantly expanded export controls on specific semiconductor and...more

Wilson Sonsini Goodrich & Rosati

BIS Expands Export Controls on Advanced Computing Integrated Circuits for Supercomputer and Semiconductor End Use, and on...

On October 17, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued new controls aimed at further slowing China’s development of advanced AI technologies. These new controls, published in two...more

BakerHostetler

Current State of BIS Export Controls in Response to the Russian Federation's Invasion of Ukraine June 2023

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On May 19, the Bureau of Industry and Security (BIS) issued two final rules expanding the export controls in the Export Administration Regulations (EAR) against the Russian Federation (Russia) for its continued war with...more

BakerHostetler

Current State of BIS Export Controls in Response to the Russian Federation's Invasion of Ukraine - March 2023

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On Feb. 24, 2023, the first anniversary of Russia’s invasion of Ukraine, the Bureau of Industry and Security (BIS) imposed further export controls on Russia and Belarus by expanding the scope of EAR99 items, including luxury...more

Sheppard

Breaking the Link – New Developments on U.S. Licenses for Exports to Huawei

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It looks like the licensing restrictions on Huawei are trickling into effect. Our sources indicate that, as early as February 27, all license applications for exports or transfers involving Huawei which were pending with...more

Torres Trade Law, PLLC

New BIS Policy Cracks Down on Uncooperative Foreign Governments With Broad Implications for Parties Trading in Goods Subject to...

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The U.S. Department of Commerce Bureau of Industry and Security (“BIS”) is cracking down on foreign governments that prevent the end-use checks the BIS uses to ensure compliance with Export Administration Regulations (“EAR”)....more

Guidepost Solutions LLC

“Chipping” Away at the Right to Fundamental Research?

New Export Control Regulations Must Be Examined to Ensure Protection of International Research Collaborations - U.S. government actions to enhance and protect U.S. technological innovation have been regularly featured in...more

Fenwick & West LLP

BIS Significantly Restricts Chinese Access to Advanced Computing and Semiconductor Manufacturing Items

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On October 7, 2022, the US Department of Commerce Bureau of Industry and Security (BIS) released two rules implementing new export controls on advanced computing and semiconductor manufacturing items in addition to new...more

Fenwick & West LLP

US Commerce Department Authorizes Release of Certain Technology and Software to All Entities on the Entity List in...

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On September 9, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (BIS or Commerce) published a rule, sought by tech and telecom companies, and industry organizations, authorizing the release of certain...more

BakerHostetler

Export Controls: A National Security Tool Implemented and Enforced By the United States and Key Allies

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On June 29, 2022 through July 1, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held its 35th Annual Update Conference on Export Controls and Policy (Update) in Washington, D.C. This important...more

BakerHostetler

Current State of BIS Export Controls in Response to the Russian Federation's Invasion of Ukraine

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Since February 24, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has implemented numerous new export control restrictions in response to the invasion of Ukraine by the Russian Federation...more

Perkins Coie

Sanctions Are the New FCPA: US Pledges Enforcement, Issues New Russia Sanctions and Export Controls

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As Russia’s invasion of Ukraine persists, with no end currently in sight, the United States continues to issue increasingly punishing economic sanctions and export controls targeting Russia, most recently aiming at the...more

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