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Export Control and Reform Act

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On November 17, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) amending and clarifying certain provisions of the Export Administration Regulations (“EAR”) to make them consistent with the Export Control Reform Act of 2018 (“ECRA”). The Final Rule also amends certain provisions of the EAR (not strictly concerning ECRA implementation) regarding the issuance of export licenses and denial orders and the payment of civil penalties.…