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Export Controls

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In brief On July 28, 2026, the Federal Communications Commission (FCC or “Commission”) added foreign-produced power inverters and advanced robotic devices to the Covered List. This placement bars new foreign-produced models from obtaining the equipment authorization required for lawful importation and marketing of radiofrequency devices unless the FCC grants Conditional Approval. This action effectuates two National Security Determinations (NSDs) that a White House-convened Executive Branch interagency body delivered to the FCC on July 27, 2026.1 Each NSD…

On August 6, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a temporary final rule (the “Rule”) that restricts exports of black mass and tungsten waste and scrap without a license. Beginning August 27, 2026, US persons that sell black mass and tungsten waste and scrap must allocate 100 percent of their monthly sales to US persons, unless they first obtain an adjustment or exception from BIS. This Rule implements…

On 23 July 2026, the European Council adopted its 21st package of Russia sanctions as well as additional measures targeting Belarus. The package concentrates on sectors with the greatest impact on Russia’s war economy, including energy, shipping, gold, financial services (including crypto), trade, and the Russian military-industrial complex. Key elements include a full-year suspension of the oil price cap adjustment, a new tool allowing transaction bans on named refineries that process Russian crude (listing one…

On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 2 (“GL 2”) under the Democratic Republic of the Congo Sanctions Regulations (the “DRCSR”) as the eastern Democratic Republic of the Congo (“DRC”) continues to face significant humanitarian challenges, including an Ebola outbreak in the region. GL 2 goes beyond the existing general license found in section 547.513 of the DRCSR, which is limited to…