Sheppard Mullin Sanctions and Export Controls Attorneys is an author at Global Trade Law Blog.
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Striking Russian Oil and The Ripple Effects
As Russian Energy Week concluded last week, Western governments strike to the heart of Russia’s energy sector with sanctions packages to cut of revenue that funds Russia’s continued war against Ukraine. Three significant packages were announced in October 2025: the U.S.’s sanctions targeting the Russian energy sector, the UK’s latest sanctions against the Russian oil industry, and the EU’s 19ᵗʰ package of sanctions.
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Not Your Usual Monday: BIS Adopts 50 Percent Rule for Entity List, MEU List & Related EAR Controls
On September 29, the Department of Commerce, Bureau of Industry and Security (BIS) published the public inspection copy of an Interim Final Rule (IFR) amending the Export Administration Regulations (EAR) to extend Entity List, Military End-User (MEU) List, and SDN-related EAR controls under § 744.8 to foreign affiliates[1] owned 50% percent or more (directly or indirectly) by listed entities. The rule will become effective on the date of publication, which is September 29.
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Keeping an EAR Out for Syria: BIS Reduces Export Controls
The pace of U.S. regulatory changes regarding Syria continues to increase. Building on our previous posts (“Syria-ous Changes for Middle East Business?” and “Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means”), we describe below the recent developments that have resulted in significant easing of export controls.
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“Lost in Transposition” – Commission Targets 18 Member States Over Sanctions Enforcement Gaps
Key Takeaways
- On July 24, 2025, the European Commission opened infringement procedures against 18 Member States for failing to fully transpose Directive (EU) 2024/1226 by the May 20, 2025 deadline.
- The Directive harmonizes criminal offences and penalties for violations of EU sanctions, including asset freeze breaches, arms embargo violations, and circumvention schemes.
- Penalties include prison sentences of up to 5 years for individuals and fines up to 5% of worldwide turnover or EUR 40 million for companies, plus additional restraining measures.
Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means
The United States has taken a historic step by terminating the Syria Sanctions Program, marking the most significant shift in U.S. foreign policy towards Syria since the fall of the Assad regime. In our earlier post, we outlined the initial steps taken by the U.S., EU, and UK to relax longstanding sanctions on Syria. Since then, the U.S. has introduced additional measures aimed at promoting commercial re-engagement, although several restrictions remain in place. Companies interested in doing business with Syria must stay current on evolving export control, sanctions, and compliance requirements.
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Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria
In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.
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A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III
A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II
A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I
The First Wave: U.S. Imposes Tariffs on Canada (or not?), Mexico (or not?), and China (well, yeah, probably so)
UPDATE: On February 5, 2025, the Trump administration issued an executive order delaying the cancellation of de minimis until “adequate systems are in place to fully and expediently process and collect tariff revenue applicable”. Imports from China below the value of $800 will generally not be subject to the 10% tariff or Section 301 duties.
Continue Reading The First Wave: U.S. Imposes Tariffs on Canada (or not?), Mexico (or not?), and China (well, yeah, probably so)