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
Export Control
Federal Government Issues Tri-Seal Advisory on Sanctions and Export Controls Relief for Syria
On November 10, 2025, the U.S. Department of State, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control, issued a Tri-Seal Advisory on sanctions and export controls relief for Syria.
The advisory provides that the United States no longer imposes comprehensive sanctions on Syria and that the…
DDTC Amends ITAR to Remove Arms Embargo on Cambodia
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…
White House Announces One-Year Suspension of the BIS “Affiliates Rule”
On November 1, 2025, the White House published a Fact Sheet announcing that the Department of Commerce’s Bureau of Industry and Security (“BIS”) will suspend the new “50% Rule”—also known as the “Affiliates Rule”—for one year, beginning November 10, 2025. The suspension was among several concessions reached during trade negotiations between the United States and…
BIS Rescinds Previous Firearms Interim Final Rule and Revises ECCNs for Firearms and Ammunition
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule in which it announced that it was rescinding in its entirety an earlier Interim Final Rule issued during President Joseph Biden’s Administration that imposed new export license requirements for firearms and related ammunition and components. The Final…
BIS Expands Entity List End-User Controls to Cover Affiliates of Listed Entities
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule that expands the export control restrictions of its Entity List to cover any affiliates that are at least 50% owned by one (or more) entities on the Entity List or the Military End-User (MEU) List. Previously…
Department of Commerce Relaxes Export Controls for Syria
On September 2, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule in the Federal Register easing licensing requirements for civilian exports to Syria. The rule implements the policy on Syria established in Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (June 30, 2025) that called for…
President Trump Signs Law Requiring Annual Report on Export Licenses Involving Certain Entities
On August 19, 2025, President Donald Trump signed the “Maintaining American Superiority by Improving Export Control Transparency Act” (H.R. 1316), amending the Export Control Reform Act of 2018 to enhance transparency from the agency responsible for administering the Export Administration Regulations (EAR). Specifically, the amendment requires the Department of Commerce’s Bureau of Industry…
President Trump Announces Revocation of Syria Sanctions and Waiver of Other Sanctions and Export Controls
On June 30, 2025, President Donald Trump issued an Executive Order (EO) that removes sanctions on Syria, provides for the issuance of waivers that will permit the relaxation of export controls and other restrictions on Syria, and otherwise seeks to support “the positive actions” taken by the new Syrian government under President Ahmed al-Sharaa. The…
BIS Adds Over 80 Companies to Entity List, with Heavy Focus on China
On March 25, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) added over 80 companies to its Entity List through two Final Rules. These are the first listings by BIS under President Donald Trump’s second term and the listings heavily focus on China. According to BIS, these entities “have been determined by…
