After much anticipation, on November 5, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released a final rule formally extending the suspension of the “Affiliates Rule” through January 10, 2027. This final rule is due to be published in the Federal Register on November 9, 2026. The Affiliates Rule, originally issued as an interim final rule effective September 29, 2025, automatically extends Entity List, Military End-User List, and certain sanctions-based licensing…
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 May 31, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance clarifying that a license continues to be required under the Export Administration Regulations (“EAR”) for exports of advanced computing items to entities located in any country, if those entities are headquartered in Country Group D:5 (including China) or Macau, or have “an ultimate parent company” headquartered in Country Group D:5 or Macau. The BIS Guidance was prompted by…