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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

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

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 implementation of new 25% Section 232 duties on steel, aluminum, and certain derivatives, effective March 12, 2025, which are in addition to any special rate of duty otherwise applicable, are affecting importers globally. Here is a breakdown of what these new tariffs entail:Continue Reading Overview of Section 232 Tariffs on Steel and Aluminum: What Importers Need to Know

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 April 16, 2025, the Department of Commerce announced that it initiated an investigation on April 1, 2025, under Section 232 of the Trade Expansion Act, into imports of semiconductors, semiconductor manufacturing equipment (SME), and related products to evaluate how those imports may impact national security.Continue Reading Who is Stacking the Chips: U.S. Commerce Department Launches Section 232 Investigation into Semiconductor Imports