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
Department of State Issues Final Rule, Effective Sept. 15, 2025, Updating ITAR and Targeted Revisions to the U.S. Munitions List
By Scott Wise, Chandler Leonard & Andrew J. Schlegel on
Posted in Export Controls, ITAR
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…
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…
BIS Updates Rules on Advanced Semiconductors
By Chandler Leonard & Andrew J. Schlegel on
Posted in Export Controls
The Department of Commerce’s (“DOC”) Bureau of Industry and Security (“BIS”) has published an interim final rule, as well as a request for comments, regarding new export controls for advanced computer, supercomputer, semiconductor, and manufacturing items. This update to the interim final rule serves to correct inadvertent errors and clarify export licensing procedures outlined in…
BIS and DDTC Amendments Add Nicaragua to EAR Country Group D and ITAR § 126.1
By Crowell & Moring on
Posted in Export Controls
On March 15, 2024, the Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) amended the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) to implement new restrictions on trade with Nicaragua.
BIS’s amendments moved Nicaragua from Country Group B to Country Group D, applying a…
Commerce, Treasury, DOJ Publish Tri-Seal Sanctions and Export Control Compliance Note
Posted in Sanctions
On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and…