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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.

  • 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

On May 8, 2025, the U.S. Department of the Treasury (Treasury) announced that it will establish a fast track review process to facilitate greater investment in the United States from ally and partner sources.  Specifically, Treasury stated that the new fast track Committee on Foreign Investment in the United States (CFIUS) review process will include

On April 30, 2025, the U.S. Department of Justice (DOJ) announced it would not prosecute the Universities Space Research Association (USRA) for alleged violations of the Export Administration Regulations (EAR). This marks the DOJ’s second declination in the last twelve months under the National Security Division’s (NSD) Enforcement Policy for Business Organizations (NSD VSD Policy)

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

As of January 15, 2025, Commerce, Energy, State, and Treasury have each published their annual increase in civil monetary penalties for violations of U.S. export controls and sanctions regulations to account for inflation.  Below is a summary of the increases for calendar year 2025.

U.S. Department of Commerce
EAR Section2024 Maximum

On January 3, 2025, President Biden issued a National Security Memorandum (NSM) to update policy guidance for the Government of the United States’ implementation of the Missile Technology Control Regime (MTCR).  The NSM directs the relevant executive branch agencies to provide increased flexibility for case-by-case review and facilitate support for certain MTCR Category I military

On August 20, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an interim final rule to 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). The interim final rule implements the proposed rule DDTC published