On February 26, 2025, Senators Jim Banks (R-Ind.) and Mark Warner (D-Va.) introduced the Maintaining American Superiority by Improving Export Control Transparency Act (the Act) in the United States Senate. A companion bill titled the same was reintroduced in the United States House of Representatives on March 5, 2025, by Congressman Ronny Jackson (R-TX-13).

The Act would amend the Export Control Reform Act of 2018 to require the Secretary of Commerce to submit an annual report to Congress on license applications, enforcement actions, and other requests for authorization for the export, reexport, release, and in-country transfer of items subject to the U.S. Export Administration Regulations (EAR) to entities: (i) located in or operating in a D:5 country; (ii) included on the U.S. Department of Commerce Bureau of Industry and Security (BIS) Entity List; or (iii) included on the BIS Military End-User List.

Specifically, the Act would require the report to include the following details for all applicable license applications or other requests for authorization: (i) the name of the entity submitting the application; (ii) a brief description of the item and its Export Control Classification Number (ECCN); (iii) the name of the end-user; (iv) the end-user’s location; (v) the value of the items; (vi) the agency’s decision with respect the license application or authorization; and (vii) the date of submission of the application.  Further, the report would require Commerce to provide the date, location, and result of any related enforcement activities, such as end-use checks and aggregate statistics on all license applications and other requests for authorizations.

Representative Jackson introduced a similar bill in the House of Representatives in December 2023, which passed the House and stalled in the Senate.

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Photo of Jana del-Cerro Jana del-Cerro

Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana

Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana works with clients across a broad range of industries, from traditional aerospace and defense manufacturers and multi-national software companies, to start-ups in the technology sector, and she regularly represents them before the Departments of State, Commerce, and Treasury in responding to government inquiries, conducting internal reviews, and in compliance investigations and voluntary disclosures.

Photo of Jeremy Iloulian Jeremy Iloulian

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. He regularly advocates on behalf of such clients before the U.S. Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls (DDTC), Office of Foreign Assets Control (OFAC), Bureau of Economic Affairs (BEA), Census Bureau, Department of Energy, and Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

Photo of Dilan Wickrema Dilan Wickrema

Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the foreign military sales process, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international

Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the foreign military sales process, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international trade and national security in the federal government to ensure clients meet their cross-border transaction goals while complying with the applicable laws and regulations. Previously, Dilan served in the Directorate of Defense Trade Controls (DDTC), the Bureau of Industry and Security, and the International Trade Administration.