The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule, effective January 15, 2026, revising the license review policy for exports from the United States of certain commercially available advanced computing semiconductors to end users in China and Macau—moving from a presumption of denial to case‑by‑case review under certain conditions. The case-by-case review policy is only available for exports meeting strict requirements, including various certifications as to sufficient supply…
After failing to pass in the previous Congress, a revised version of the “BIOSECURE Act” (“the Act”) was signed into law by President Trump on December 18, 2025, as Section 851 of the National Defense Authorization Act (“NDAA”) for Fiscal Year 2026 (P.L. 119-60). The new law will restrict US federal procurement and grants involving biotechnology products or services provided by “biotechnology companies of concern” (“BCC”). While amended and clarified in key areas, the Act…
On December 18, 2025, President Trump signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2026 (P.L. 119-60). A must-pass piece of legislation that funds Department of Defense (“DoD”) operations on an annual basis, the NDAA is a frequent vehicle for trade-related provisions and legislative changes affecting DoD acquisition policies with direct implications for government contractors. The NDAA includes a number of provisions relating to US sanctions, investment security, and supply chain…
On November 14, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended two general licenses and issued two new general licenses (“GLs”)authorizing limited transactions involving Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) and entities in which they respectively own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively “Rosneft and Lukoil Entities”). Rosneft and Lukoil…