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
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OFAC Launches New Online Voluntary Self-Disclosure Portal
Posted in Office of Foreign Assets Control (OFAC), Sanctions
On February 6, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) announced the launch of a new online Voluntary Self-Disclosure (VSD) Portal (the “New Portal”) intended to replace and reduce reliance on ad hoc submission methods with a more secure channel for reporting to OFAC potential sanctions violations. OFAC states that…
BIS Fines Exyte $1.5 Million for Unlicensed Transfers to China’s SMIC
By Jeremy Iloulian & Nate Young on
On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $1.5 million civil penalty on Exyte Management GmbH (“Exyte”), a Germany- headquartered engineering and procurement company, after its Shanghai affiliate Exyte Shanghai Ltd., (“Exyte China”) admitted to illegally causing the transfer of approximately $2.8 million in EAR-subject semiconductor…
Treasury Authorizes Transactions with Belarusian Potash Companies
By Erik Woodhouse, Sophie Davis & Nate Young on
On December 15, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Belarus General License 13, “Authorizing Transactions Involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO.” The general license authorizes all transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 (“BSR”), involving Joint Stock Company…
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
By Scott Wise, Chandler Leonard & Nate Young on
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
By Scott Wise, Jeremy Iloulian, Chandler Leonard & Nate Young on
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
By Chandler Leonard & Nate Young on
Posted in Export Administration Regulations (EAR)
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…