- 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
U.S. Department of the Treasury to Establish Fast Track CFIUS Process for Foreign Investors
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
DOJ Declines Prosecution of Company for Employee’s Unlawful Export
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)
BIS Adds and Removes Persons from the Unverified List
On April 25, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule that added 18 new persons and removed five persons from the Unverified List (UVL).
Of the 18 persons added in the UVL, five are located in China, six are located in Finland, three are located in
President Trump Signs Executive Order Regarding U.S. Defense Trade
On April 9, 2025, President Trump signed and released an Executive Order (EO) to “improve speed and accountability” in the U.S. defense trade system and published an accompanying fact sheet. The EO identifies specific actions for executive branch agencies to take including: (i) reverting back to the Conventional Arms Transfer Policy that President Trump
Improving Export Control Transparency Act Introduced to Increase Transparency Regarding the Approval of Exports to Specific Countries and End-Users
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
U.S. Export Controls and Sanctions Regulatory Agencies Increase Civil Monetary Penalties for Violations
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 Section | 2024 Maximum | |
Biden Administration Updates Policy Guidance for the Implementation of the Missile Technology Control Regime
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
DDTC Increase in Registration Fee Rates Become Effective
On January 9, 2025, DDTC’s new registration fee rates become effective. This is the first time in fifteen years DDTC has increased the registration fees charged to those who are required to register with DDTC pursuant to the Arms Export Control Act. Pursuant to the final rule amending parts 122 and 129 of the ITAR
DDTC Publishes ITAR Amendments to Implement the AUKUS Exemption
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