Export Controls

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Capping off a highly eventful week in Asia at the end of October, President Donald J. Trump has further reshaped the landscape of U.S. trade with the Asia-Pacific region through a series of new agreements. This latest round of negotiations includes new reciprocal trade deals and market access commitments across Cambodia, Thailand, Malaysia, Vietnam, China, South Korea, and Japan. Some of these agreements build upon the foundation laid by Executive Order 14346 (Sept. 5, 2025). That order provided for zero percent tariffs on products listed in Annex III, once a qualifying trade deal was announced.[1] With some agreements now in place, Annex III of the EO is being actively implemented.Continue Reading Shifts in U.S. Trade in Asia: Key Agreements from President Trump’s October 2025 Asia Trip – Part II: East Asia

Capping off a highly eventful week in Asia, President Donald J. Trump has further reshaped the landscape of U.S. trade with the Asia-Pacific region through a series of new agreements. This latest round of negotiations includes new reciprocal trade deals and market access commitments across Cambodia, Thailand, Malaysia, Vietnam, China, South Korea, and Japan. Some of these agreements build upon the foundation laid by Executive Order 14346 (Sept. 5, 2025). That order provided for zero percent tariffs on products listed in Annex III, once a qualifying trade deal was announced.[1] With some agreements now in place, Annex III of the EO is being actively implemented.Continue Reading Shifts in U.S. Trade in Asia: Key Agreements from President Trump’s October 2025 Asia Trip – Part I: Southeast Asia

Update (November 2025): BIS suspended implementation of the Affiliates Rule for one year, temporarily reversing the extension of Entity List and MEU-related controls to foreign affiliates that are 50% or more owned by listed entities. In a final rule effective November 10, 2025, BIS stayed the interim rule’s amendments to the EAR until November 9, 2026, absent further extension. During the suspension period, the EAR reverts to the prior “legally distinct” test, meaning foreign affiliates are not automatically covered solely by virtue of 50% ownership. The suspension comes as result of trade negotiations with China, which we discuss our recent blog series on U.S. Trade in Asia.Continue Reading Not Your Usual Monday: BIS Adopts 50 Percent Rule for Entity List, MEU List & Related EAR 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.Continue Reading Keeping an EAR Out for Syria: BIS Reduces Export Controls

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.Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria

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

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

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

On December 2, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) issued a new set of regulations targeting semiconductors manufacturing equipment (SME) and high-bandwidth memory (HBM) chips. The updates are a part of BIS’s ongoing efforts to target semiconductors in attempt to slow down China’s advancement of AI. In the race to artificial general intelligence, advanced-node semiconductors play an outsized role in a country or company’s ability to progress.Continue Reading The Persistence of (High Bandwidth) Memory: Semiconductor Manufacturing Equipment and Korean Semiconductor Manufactures Face Harsher Restrictions Under New HBM Rules