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…
On November 10, 2025, the US Department of the Treasury, US Department of State, and US Department of Commerce issued a Tri-Seal Advisory (see here) summarizing the current scope of US sanctions and export controls relief measures applicable to Syria. The document serves as a consolidated reference point for the actions taken so far to relax US sanctions and export controls for Syria, including those aimed at facilitating humanitarian assistance and early recovery efforts. The…
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…
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,…