Topic
Export Control
1,332 published works
International Trade Law
BIS Adds 26 Entities, Mostly in China, to the Entity List for Supplying Iran with Drone Parts and U.S.-Origin Electronic Items
By Scott Wise, Jeremy Iloulian, Chandler Leonard, Nate Young
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule on October 9, 2025 that will add 26 entities and three addresses to the Entity…
Global Policy Watch
U.S. Department of Commerce Expands End-User Controls to Cover Affiliates of Certain Listed Entities
By Peter Flanagan, Kimberly Strosnider, Peter Lichtenbaum, Eric Carlson, Stephen Rademaker, Corinne Goldstein, Eric Sandberg-Zakian, Stephen Bartenstein, Joshua Williams, Adam Szubin, Alan Estevez, Seth Atkisson, Caroline Garth, Shanelle Van
On September 29, 2025, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued an interim final rule titled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities (the…
International Trade Law
BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists
By Scott Wise, Jeremy Iloulian, Chandler Leonard, Jackie Schaeffer
In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most…
Beyond the First 100 Days
US Commerce Department Adopts “Affiliates Rule” Expanding Export Restrictions
This measure significantly expands the scope of Entity List and Military End-User List restrictions, imposing heightened diligence obligations and complicating EAR compliance. By Les P. Carnegie, Damara L. Chambers, Charles…
Regulatory Oversight
Dissecting the Nuances of BIS’s New Affiliates Rule
By Peter Jeydel, Ryan Last, Charlene Goldfield
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) recently implemented the long-anticipated 50% ownership standard (or Affiliates Rule) to extend the licensing requirements under the Export Administration…
Constructlaw®
Government Contractors and the Fall 2025 Government Shutdown: Risk Management and Best Practices
By Michael Barnicle, Hilary Cairnie, Peter Jeydel, Bonnie Gill, Trey Smith, Bryan Williamson
Shutdown, again. This advisory helps contractors manage operations during this period. First Step for Government Contractors and Companies Subject to US Export Controls. Contractors should closely monitor their customer and…
Global Trade & Sanctions Law
Commerce Department Issues “Affiliates Rule,” Extends Entity List Restrictions to Majority-Owned Foreign Entities
By Stephan E. Becker, Matthew R. Rabinowitz, Sahar J. Hafeez, Julian M. Beach, Samantha Franks, Taishu Pitt
On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a long-anticipated interim final rule (IFR) amending the Export Administration Regulations (EAR) to extend…
GovCon & Trade
BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities
Please note that the content below was posted on October 2, 2025. We have since provided updated guidance on the topics discussed in this post here. On September 29, the U.S.…
Regulatory Oversight
Government Contractors and the Fall 2025 Government Shutdown: Risk Management and Best Practices
By Michael Barnicle, Hilary Cairnie, Peter Jeydel, Bonnie Gill, Trey Smith, Bryan Williamson
Shutdown, again. This advisory helps contractors manage operations during this period. First Step for Government Contractors and Companies Subject to US Export Controls. Contractors should closely monitor their customer and…
Cleary Foreign Investment and International Trade Watch
BIS Significantly Expands Application of Export Control Restricted Party Lists with New “Affiliates Rule”
By Chase D. Kaniecki, Samuel H. Chang, Catherine Johnson
On November 1, 2025, following U.S.-China trade discussions, the White House announced that it would suspend implementation of the Affiliates Rule for one year. Effective November 10, 2025, BIS imposed…