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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…

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…

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…

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…

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…

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…

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…

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…

On February 6, 2025, the State Department republished the “Cuba Restricted List” identifying entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel. The Cuba Restricted List is significant because direct financial transactions with the enumerated entities and subentities are…

On January 15, 2025, the Department of Commerce’s inflation-adjusted civil monetary penalties for 2025 went into effect. The adjustments, which the Department of Commerce (“Commerce”) published in the Federal Register on December 30, 2024, update the penalty rates for violations of laws and regulations enforced by the agency and its bureaus. 

While over 40 civil…