Following months of negotiations and feints, on November 1, 2025, the United States and China reached a trade and economic agreement during bilateral discussions held in the Republic of Korea. The agreement outlines a series of reciprocal measures intended to address trade flows and market access between the two countries. The negotiations had already yielded significant rapprochement between the two countries, including the one-year suspension, as of November 10, 2025, of the “Affiliates Rule,” which…
On October 30, 2025, US Secretary of Treasury Scott Bessent announced that the United States will pause enforcement of the US Department of Commerce Bureau of Industry and Security’s (“BIS”) “Affiliates Rule” for one year. The rule was set to impose certain end user licensing requirements and restrictions under the Export Administration Regulations to unlisted foreign affiliates owned 50% or more by one or more entities on any of the Entity List, Military End-User List,…
On September 29, 2025, after some months of speculation, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities” (the “IFR”). The IFR immediately introduces a new “Affiliates Rule,” essentially a “50% ownership flow-down rule,” into the Export Administration Regulations (“EAR”). This marks a major shift in US export control policy by automatically extending certain EAR end user…
On July 22, 2025, the US Senate unanimously passed the Maintaining American Superiority by Improving Export Control Transparency Act (H.R. 1316), sending it to President Trump for his signature. The Act would amend the Export Control Reform Act of 2018 (“ECRA”) to require the Secretary of Commerce to submit an annual report to Congress on license applications, enforcement actions, and other requests for authorization handled by the US Commerce Department’s Bureau of Industry and Security…