On August 27, 2025, the Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR”) and updating the U.S. Munitions List (“USML”). The rule, effective September 15, 2025, implements changes following public comment and periodic review required under the Arms Export Control Act.
The latest ITAR amendments remove certain items
Export Controls
BIS Announces Addition of 32 Entities to the Entity List, Including For Exports to Russia
By Scott Wise, Jeremy Iloulian & Ivy Xun on
On September 12, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released a final rule that announced the addition of 32 new entities to the Entity List (see BIS final rule here). 23 entities were added under the destination of China, one under India, one under Iran, one under…
President Trump Signs Amendment to Export Control Reform Act
By Scott Wise, Jeremy Iloulian & Edward Goetz on
Posted in Export Controls
On August 19, President Trump signed the Maintaining American Superiority by Improving Export Control Transparency Act (H.R. 1316) after the House passed it by voice vote, and the Senate unanimously voted in favor.
The bill amends the Export Control Reform Act of 2018 (ECRA) by requiring the Bureau of Industry and Security (BIS)…
Joint Criminal and Civil Export Controls Enforcement: Lessons from the Cadence Case
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…
SNAP-R Legacy Site to be Decommissioned June 30, Migrating to New Platform
By Jeffrey L. Snyder, Pierfilippo M. Natta & Ivy Xun on
Posted in Export Controls
The current version of SNAP-R will be decommissioned on June 30, 2025, and a new SNAP-R site and URL (https://snapr.bis.gov/) is taking its place. All current users should migrate their SNAP-R accounts from the decommissioned site to the new platform for continued access. Each user’s account must be migrated individually, and it is…
U.S. Department of Commerce Rescinds Biden Administration’s AI Diffusion Export Control Rule and Issues New Guidance on Huawei, Chips for AI Purposes, and Diligence Expectations
- 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
BIS Rescinds Biden Administration’s AI Diffusion Export Control Rule
By Jeffrey L. Snyder, Jeremy Iloulian & Edward Goetz on
The Bureau of Industry and Security (BIS) announced plans on May 13,2025, to rescind the Biden Administration’s AI diffusion export control rule, which was set to take effect on May 15. BIS will issue a formal rescission notice in the Federal Register and plans to introduce a replacement rule in the future. BIS enforcement officials…
DOJ Declines Prosecution of Company for Employee’s Unlawful Export
Posted in Export Controls
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)…
President Trump Signs Executive Order Regarding U.S. Defense Trade
By Crowell & Moring on
Posted in Export Controls
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
By Jeremy Iloulian on
Posted in Export Controls
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…