Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

Client Advisory: BIS Expands Entity List Jurisdiction Covering Huawei and Affiliates

By Meredith Rathbone, Wendy Wysong, Jack Hayes, Hena Schommer & Peter Jeydel on May 26, 2020
Email this postTweet this postLike this postShare this post on LinkedIn

On May 19, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a new interim final rule, retroactively effective on May 15, amending the Foreign-Produced Direct Product Rule (FPDP) under the US Export Administration Regulations (EAR). The new rule expands the jurisdictional scope of the EAR and restricts the non-US supply of semiconductor chips to Huawei Technologies and its affiliates on the Commerce Department Entity List (Supplement No. 4 to 15 C.F.R. Part 744).

Some aspects of the rule are subject to a “savings clause” or delay in application of the new restrictions. BIS will be accepting comments regarding the interim final rule until July 14.

For more on this issue, read our Client Advisory.

Photo of Meredith Rathbone Meredith Rathbone

Meredith Rathbone focuses on export controls and economic sanctions, and has assisted clients in the energy, manufacturing, telecommunications, information security, banking, insurance, pharmaceutical, and service industries, among many others, in navigating the requirements of the Export Administration Regulations (EAR), International Traffic in Arms…

Meredith Rathbone focuses on export controls and economic sanctions, and has assisted clients in the energy, manufacturing, telecommunications, information security, banking, insurance, pharmaceutical, and service industries, among many others, in navigating the requirements of the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR) and US sanctions regulations administered by the Office of Foreign Assets Control (OFAC) and US Department of State. She regularly assists companies in developing compliance policies, conducting internal investigations, performing training, and conducting due diligence in M&A transactions. She has represented individuals and companies facing civil and criminal investigations in this area, and has also represented clients in their efforts to be removed from OFAC’s list of Specially Designated Nationals (SDNs). She is a frequent writer and speaker on export controls and sanctions topics. She is the co-chair of the American Bar Association’s Export Controls and Economic Sanctions Committee, and also serves on the Sanctions Subcommittee of the State Department’s Advisory Committee on International Economic Policy.

Read Meredith’s full bio.

Read more about Meredith RathboneEmail
Show more Show less
Photo of Jack Hayes Jack Hayes

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and…

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and post-closing acquisition export compliance due diligence, export control audits, and assessments of compliance obligations and risks in accordance with relevant international trade regulations. He also provides guidance on brokering requirements and reporting obligations for certain fees, commissions, and political contributions related to sales of defense articles and defense services, prepares export and reexport license and agreement applications for submission, undertakes commodity jurisdiction and export classification analyses of items and services under the ITAR and EAR, drafts registration material change notifications, and develops compliance policies, programs, and training materials.

Read Jack’s full bio.

Read more about Jack HayesEmail
Show more Show less
Photo of Peter Jeydel Peter Jeydel

Peter Jeydel‘s practice focuses on US export controls and economic sanctions, including the Commerce Department’s Export Administration Regulations (EAR), the State Department’s International Traffic in Arms Regulations (ITAR), and sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC)…

Peter Jeydel‘s practice focuses on US export controls and economic sanctions, including the Commerce Department’s Export Administration Regulations (EAR), the State Department’s International Traffic in Arms Regulations (ITAR), and sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the State Department. His practice spans all aspects of these regimes, including counseling, compliance, transactional advice, licensing and opinions, disclosures, and enforcement actions. He has also represented companies and individuals seeking de-listing from OFAC’s sanctions list. In addition, Pete has assisted clients in anti-corruption matters, including under the US Foreign Corrupt Practices Act (FCPA), and has experience handling reviews and investigations by the Committee on Foreign Investment in the United States (CFIUS).

Read Pete’s full bio.

Read more about Peter JeydelEmail
Show more Show less
  • Posted in:
    Administrative and Regulatory
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo