On August 26, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule removing the Syrian Sanctions Regulations (31 CFR Part 542) from the Code of Federal Regulations (“OFAC Final Rule”). This action follows the issuance of Executive Order (“EO”) 14312 on June 30, 2025, which terminated the national emergency declared in EO 13338 and revoked multiple Syria-related sanctions authorities. Our blog post on the issuance of EO…
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…
On June 30, 2025, the White House reissued National Security Presidential Memorandum-5 (“2025 NSPM-5”) focused on Cuba policy that it published in largely the same form in the first Trump Administration (see the “2017 NSPM-5”). As acknowledged in Section 4(a) of the reissued document, much of the contents of the 2025 NSPM-5 was already implemented in the first Trump Administration pursuant to the 2017 NSPM-5. Along with 2025 NSPM-5, the White House issued a related…
On May 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) initiated a rescission of the Biden Administration’s AI Diffusion Rule, which was issued on January 15, 2025 and had been set to take effect on May 15, 2025. The AI Diffusion Rule had introduced additional expansive and complex export controls on certain advanced computing integrated circuits (“IC”) and on model weights for certain advanced closed-weight artificial intelligence (“AI”) models. Our…