Export controls and economic sanctions have remained an active and evolving area of laws and regulations that continue to impact the aviation industry in 2025 – both contributing to and arising as a result of an increasingly...more
China’s Ministry of Foreign Affairs (MOFA) on December 26, 2025, issued the country’s latest round of sanctions pursuant to its Anti-Foreign Sanctions Law (or AFSL), targeting US companies and US-based individuals engaged in...more
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
Secretary Pete Hegseth announced details of sweeping reforms aimed at promoting competition, reducing bureaucracy, and accelerating the delivery of capabilities to warfighters at a speech at the National War College on...more
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
Key Takeaways In a significant—but anticipated—change to the U.S. export control regime, the Bureau of Industry and Security (BIS) released an interim final rule amending the Export Administration Regulations (EAR) by...more
Doing business in Syria has become a little easier. Combined efforts by the Treasury Department’s Office of Foreign Assets Control (OFAC) in removing comprehensive Syria sanctions and the Commerce Department’s Bureau of...more
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
On September 29, 2025, the Bureau of Industry and Security (BIS) published a new “50 percent rule” expanding export controls under the Export Administration Regulations (EAR). This rule subjects any foreign entity that is 50%...more
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
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently implemented the long-anticipated 50% ownership standard (or Affiliates Rule) to extend the licensing requirements under the Export...more
On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a rule, effective immediately, that amended the Export Administration Regulations to address diversion concerns regarding...more
This measure significantly expands the scope of Entity List and Military End-User List restrictions, imposing heightened diligence obligations and complicating EAR compliance....more
Pursuant to the new “Affiliates Rule,” the Entity List license requirements now apply to any foreign entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more listed...more
On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) announced it was extending restrictions imposed by its Entity List and its Military End User (“MEU”) List to organizations...more
In response to national security concerns regarding shipments of export-controlled items diverted to entities on the Entity List and other U.S. restricted parties lists, the U.S. Department of Commerce, Bureau of Industry and...more
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
On September 29, 2025, the United States significantly expanded the reach of export controls. The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") released an interim final rule, that applies Entity List...more
On September 29, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a new interim final rule that significantly expands the scope of U.S. export controls. Entitled Expansion of End-User Controls to...more
The Department of Commerce’s Bureau of Industry and Security (BIS) has published an interim final rule (the Affiliates Rule) expanding the standard for entities captured under BIS export restrictions to include entities with...more
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
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
On September 29, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) released a long-anticipated interim final rule (IFR) that will result in the most dramatic expansion of U.S. export control...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released an interim final rule that automatically applies Entity List and Military End User (“MEU”) List restrictions to any entity that is 50% or more...more
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