On November 10, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) formally suspended the implementation of the “Affiliates Rule” for one year, as published in the Federal Register (linked here) on November 12, 2025. This suspension follows high-level trade negotiations between the United States and China, culminating in reciprocal concessions announced in late October and early November as discussed on our blog here and here. Background on the Affiliates Rule Originally…
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 October 21, 2025, the US Department of Commerce’s International Trade Administration (“ITA”) announced the implementation of the July 23, 2025 Executive Order (“EO”) Promoting the Export of the American AI Technology Stack (the “American AI Exports Program”). Following our earlier post addressing the White House’s AI Action Plan and the EO, this update focuses on the implementation of the EO and the ITA’s request for public feedback. As a reminder, the EO directs the Secretary…