Key Takeaways: The Bureau of Industry and Security (“BIS”) issued a temporary final rule under the Defense Priorities and Allocations System (“DPAS”) that restricts exports of shredded lithium-ion battery scrap containing cathode material, known as “black mass,” as well as tungsten and other waste by U.S. entities. Published on August 6, 2026, and effective immediately
Chandler Leonard
Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.
State Department Proposes ITAR Part 130 Amendments to Reduce Defense Sales Reporting Burden
Key Takeaway: DDTC’s proposed rule would shift ITAR Part 130 reporting from a transaction-linked model to consolidated annual submissions. It also proposes raising monetary thresholds for the first time since 1993. By making notifications of political contributions and fees or commissions related to foreign arms sales simpler and clearer, the proposal will make reporting more…
BIS Confirms Advanced Chip License Requirements Extend to D:5 and Macau-Headquartered Entities Worldwide
Key Takeaway: BIS’s latest guidance closes an ambiguity created by the AI Diffusion Rule rollback, confirming that the original 2023 license requirement for advanced computing items exported to Country Group D:5 and Macau-headquartered entities remains in full force – regardless of where those entities are physically located.
On May 31, 2026, the U.S. Department of…
ATF Catches Up with Export Control Reform (Better Late than Never!)
Key Takeaway: ATF’s latest final rule closes a regulatory gap left by the Export Control Reform (“ECR”) initiative, acknowledging that the Department of Commerce now shares jurisdiction alongside the Department of State over items on ATF’s United States Munitions Import List (“USMIL”).
On May 6, 2026, the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”)…
BIS Fines Teledyne FLIR $1 Million for Unlicensed China-Related Thermal Camera Exports and De Minimis Miscalculations
On February 26, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) reached an administrative enforcement settlement with Teledyne FLIR LLC and its affiliates FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems, Inc. d/b/a Teledyne FLIR OEM, (together, “Teledyne FLIR”), imposing a $1,000,000 civil penalty to resolve alleged violations…
Treasury Seeks Public Input on CFIUS Known Investor Program and Streamlining of Foreign Investment Reviews
On February 9, 2026, the U.S. Department of the Treasury’s (Treasury) Office of Investment Security (OIS) published a request for information (RFI) seeking public comments on how the Committee on Foreign Investment in the United States (CFIUS) might streamline its foreign investment review process, including through the Known Investor Program (KIP). The RFI requests feedback…
European Commission Revises Dual-Use List: Highlights from the 2025 Update
On November 15, 2025, the implementing regulation updating the EU’s Dual-Use Regulation (Regulation (EU) 2021/821) came into force. The update incorporates editorial refinements for greater clarity and coherence, introduces new entries, and further clarifies some existing ones.
These updates reflect the EU’s efforts to harmonize its export controls with recent decisions and commitments…
State Department Removes Cambodia from ITAR 126.1 Proscribed Countries List
The U.S. Department of State (“State”) has decided to lift the defense trade embargo against Cambodia. Accordingly, the Directorate of Defense Trade Controls (“DDTC”) will publish on November 7, 2025, a final rule amending the International Traffic in Arms Regulations (ITAR) at § 126.1 to remove Cambodia from the proscribed countries list.
For countries included…
BIS Adds 26 Entities, Mostly in China, to the Entity List for Supplying Iran with Drone Parts and U.S.-Origin Electronic Items
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule on October 9, 2025 that will add 26 entities and three addresses to the Entity List for a total of 29 new entries (effective immediately). BIS’ Entity Review Committee (ERC)—composed mainly of the Departments of Commerce, State, Defense, Energy, and…
Department of Commerce Restores Firearms Licensing Policy of First Trump Administration, Rescinds Biden Restrictions
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule rescinding an interim final rule (IFR) introduced by the Biden administration. This IFR had imposed new export licensing requirements on civilian firearms and related ammunition and components. In its press release, BIS stated that the previous…