Export Administration Regulations (EAR)

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Key Takeaways: The UAE’s reclassification to Country Group A:5 in the U.S. Export Administration Regulations (“EAR”) is one of the most significant expansions of U.S. export licensing flexibility extended to a Middle Eastern partner in recent years. Exporters should promptly assess whether existing licensed shipments or pending BIS applications can now be restructured under a…

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR)…

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…

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”)…

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…

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…

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…

On July 28, 2025, Cadence Design Systems Inc., a global electronic design automation technology company based in San Jose, California, agreed to plead guilty to export violations in a settlement with the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the Northern District of California, and resolved a civil enforcement…

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…