Export Administration Regulations (EAR)

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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…

In new guidance published on October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued recommendations about its expectations for financial institutions in complying with U.S. export control obligations.

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On September 12, 2024, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a final rule to amend the Export Administration Regulations (EAR) revising provisions related to the voluntary self-disclosure (VSD) process for persons who believe that they may have violated the EAR, or any order, license or authorization issued thereunder. The…

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…

The U.S. Department of Commerce, Bureau of Industry and Security (BIS), published a final rule on February 23, 2024, amending the Export Administration Regulations (EAR) by revising license requirements for certain cameras, systems, and related components to eliminate license requirements for certain cameras to Country Group A:1. In addition to these changes, BIS is adding…

On December 29, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published a series of Frequently Asked Questions (FAQs) addressing comments received on the October 13, 2022 interim final rules that amended, and in some cases expanded, U.S. export restrictions on semiconductor manufacturing items and advanced computing items and end uses. …

On December 19, the Bureau of Industry and Security (“BIS”) added 13 new entities to its Unverified List (“UVL”). All 13 of these entities were added under the destination of the Peoples’ Republic of China (“PRC”) on the basis that BIS was unable to verify their bona fides.

The UVL contains the names and addresses…

On April 18, 2023, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) released a memorandum entitled, “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning Others” (the “April Memo”).  The April Memo highlights additional penalties and incentives to encourage exporters – and whistleblowers – to disclose potential violations of the…

On March 28th, BIS issued a final rule amending the Export Administration Regulations (EAR) to confirm that protecting human rights worldwide is a basis for adding entities to the Entity List. Additionally, BIS added 11 entities from Burma, China, Nicaragua, and Russia to the Entity List.

As reflected in the decision by the…

On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) simultaneously published a final rule strengthening the antiboycott regulations in Part 766 of the Export Administration Regulations (EAR) (the “Final Rule”), as well as a memorandum on the new rule’s implementation (the “Final Rule Memo”), issued by the Assistant Secretary…