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
House Passes Remote Access Security Act to Limit Adversaries’ Remote Access to Critical Technology
By Scott Wise, Jeremy Iloulian & Dmitry Bergoltsev on
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…
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…
BIS Adds 26 Entities, Mostly in China, to the Entity List for Supplying Iran with Drone Parts and U.S.-Origin Electronic Items
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…
BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists
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…
BIS Opens Inclusions Window for Section 232 Steel and Aluminum Tariffs
By Daniel Cannistra, Valerie Ellis & Emily Devereaux on
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…
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…
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…
Export Controls and America’s AI Action Plan
By Scott Wise, Jeremy Iloulian & Tim Laderach on
Posted in AI
On Wednesday, July 23, 2025, the White House released the “America’s AI Action Plan” (the “AI Action Plan”). The AI Action Plan is the result of the Trump Administration’s Request for Information, which describes policy actions related to artificial intelligence as it seeks to replace the Biden Administration’s “AI Diffusion Rule.” The…
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