On August 6, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a temporary final rule (the “Rule”) that restricts exports of black mass and tungsten waste and scrap without a license. Beginning August 27, 2026, US persons that sell black mass and tungsten waste and scrap must allocate 100 percent of their monthly sales to US persons, unless they first obtain an adjustment or exception from BIS. This Rule implements…
On July 10, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”), providing enhanced favorable treatment to the United Arab Emirates (“UAE”) under the Export Administration Regulations (“EAR”). BIS indicates the change is a recognition of the UAE’s status as a US Major Defense Partner, its key role in advancing US national security interests including during Operation Epic Fury, its commitment to implementing effective export…
On July 8, 2026, the US Department of State announced that President Trump had notified Congress of his administration’s intent to rescind Syria’s designation as a State Sponsor of Terrorism (“SST”). The notification initiates a 45-day period that must elapse before the rescission takes effect. In the accompanying press statement, Secretary of State Marco Rubio said that “[l]ifting sanctions on Syria will unlock international trade and investment, give Syria a chance to rebuild, and open…
On June 11, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published in the Federal Register the List of Medical Devices Requiring Specific Authorization under the North Korea Sanctions Regulations, 31 CFR Part 510 (“NKSR”). The export or reexport of these excluded non-US medical devices to North Korea requires a specific license from OFAC if US Persons are involved. Other non-US medical devices remain eligible for export/reexport to North Korea…