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…
As of October 1, 2025, the US government partially shut down as federal funding lapsed for numerous US government agencies, including those engaged in export controls, sanctions, and foreign investment. As a result, companies should expect licensing processing and reviews to be significantly delayed. Investigative activity and enforcement actions related to US national security, however, will continue as agencies and federal workers deemed “essential” will continue to carry out such operations. Below is an overview…
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…