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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.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

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.

Continue Reading “Lost in Transposition” – Commission Targets 18 Member States Over Sanctions Enforcement Gaps

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.Continue Reading Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means

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

Grants and tax credits, who doesn’t love them? The Bipartisan Infrastructure Law (BIL) is full of them, and recent Department of Energy (DOE) Notification of a Proposed Interpretive Rule provides guidance on who will get to benefit from those grants and tax credits. The BIL is a historic investment in U.S. infrastructure, the breadth of which is beyond the scope of this blog. However, thankfully, the DOE Proposed Rule focuses on batteries.Continue Reading Should You Be Concerned About Foreign Entities of Concern?