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Key Takeaways: The Bureau of Industry and Security (“BIS”) issued a temporary final rule under the Defense Priorities and Allocations System (“DPAS”) that restricts exports of shredded lithium-ion battery scrap containing cathode material, known as “black mass,” as well as tungsten and other waste by U.S. entities. Published on August 6, 2026, and effective immediately…

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)…

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 12, 2026, the U.S. House of Representatives overwhelming passed (369-22) the Remote Access Security Act, modernizing U.S. export controls to address foreign adversaries’ remote access to controlled technologies through cloud computing services.  

Currently, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) does not consider the provision of cloud computing…

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…

In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more by one or…

The Bureau of Industry and Security (BIS) announced via Federal Register Notice the opening of the window to submit requests to include additional derivative products under the Section 232 steel and aluminum tariffs. The window opened on September 15, 2025 and is set to close on September 29, 2025, at 11:59 PM (EST). Requests are…

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…

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…