On November 7, 2025, the State Department’s Directorate of Defense Trade Controls (DDTC) issued a Final Rule amending 22 C.F.R. § 126.1 to remove the Kingdom of Cambodia as a proscribed country under the International Traffic in Arms Regulations (ITAR).  Effective immediately, requests for the export of defense articles and services to Cambodia will now be considered on a case-by-case basis.

For years, the United States had prohibited exports and sales of defense articles and services to Cambodia absent a license from DDTC, and any license application was reviewed under a policy of denial.  Pursuant to the final rule,  “[b]ased on Cambodia’s diligent pursuit of peace and security, including through renewed engagement with the United States on defense cooperation and combating transnational crime, the Secretary of State made a determination to lift the embargo on defense trade with Cambodia.”

This action comes after the United States and Cambodia reached a trade deal on October 26, 2025.  See Thompson Hine Update of October 28, 2025.

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.