On February 3, 2026, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule removing Cambodia from the list of U.S. arms-embargoed countries—Country Group D:5—within the Export Administration Regulations (“EAR”). This actions follows the White House’s October 2025 decision to lift the U.S. arms embargo on Cambodia, and aligns with the Department of State’s Directorate of Defense Trade Controls corresponding final rule from November 2025 that amended the International Traffic in Arms Regulations (“ITAR”) by withdrawing Cambodia as a proscribed country (see Update of November 7, 2025).
In the final rule, BIS explained the amendment related to Cambodia was necessary for two principal reasons. First, according to the final rule, the change reflects “Cambodia’s diligent pursuit of peace and security, including through renewed engagement with the United States on defense cooperation and combating transnational crime.” Second, following the November 2025 ITAR amendment, Cambodia remained listed as an arms-embargoed destination under the EAR, even though the EAR provide that discrepancies between it and the ITAR are controlled by the ITAR, causing “confusion on the part of exporters, reexporters, and transferors over differences between the list of countries subject to an arms embargo [when juxtaposing] both regulations.”
The specific amendment related to Cambodia appears in Supplement No. 1 to Part 740 of the EAR, which lists the various country groups. Although Cambodia has now been removed from Country Group D:5, it remains in Country Group D, which applies heightened export controls to the jurisdictions is covers, and, more specifically, in Country Group D:1, which imposes controls based on national security concerns. Cambodia also remains subject to the military and military-intelligence end-use and end-user restrictions set forth in sections 744.21 and 744.22 of the EAR.