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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.

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…

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…

In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more by one or…

On August 27, 2025, the Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR”) and updating the U.S. Munitions List (“USML”). The rule, effective September 15, 2025, implements changes following public comment and periodic review required under the Arms Export Control Act.

The latest ITAR amendments remove certain items…

  • Key takeaway #1The new guidance amounts to prohibitions on U.S. and non-U.S. persons using, selling, transferring, financing, or servicing Huawei’s Ascend 910B, 910C, and 910D chips, as well as other comparable chips from other Chinese companies.
  • Key takeaway #2While the U.S. Department of Commerce Bureau of Industry and Security (BIS) has issued some advanced computing-related
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On March 25, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”)  released two final rules that announced the addition of 80 new entities to the Entity List (see BIS press release here). In its press release, BIS officials stated that the Entity List is only one of the powerful…

On July 25, 2024, the U.S. Departments of State and Commerce issued new proposed rules that, if implemented, would (1) increase the restrictions associated with U.S. persons providing services in support of non-U.S. military-related end users / uses; and (2) implement new controls associated with exports, reexports, and transfers of items subject to the EAR…

On May 1, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a proposed rule that, if implemented, would streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership).

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The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has published proposed regulatory amendments that, if implemented, would expand CFIUS’s authority to seek information for non-notified transactions, establish timelines for parties to respond to CFIUS’s mitigation proposals, and increase penalties for certain violations to the greater of $5 million or the…

On April 19, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to enhance technological innovation and support the goals of the AUKUS trilateral security partnership.

The interim final rule makes six primary export control policy changes that effectively provide Australia and the UK nearly the same…