Export Administration Regulations compliance
Export Administration Regulations compliance in the Energy, Power & Commodities sector has grown materially more demanding since the Bureau of Industry and Security expanded its Entity List and tightened EAR99 classification reviews for dual-use energy technologies, including power grid components and LNG infrastructure equipment. The U.S. Department of Commerce's Bureau of Industry and Security and the Office of Foreign Assets Control are the primary federal authorities setting the tempo here, with the U.S. Department of Energy's Office of Electricity holding concurrent jurisdiction over certain cross-border electricity transfer authorizations. Compliance teams in this sector are currently stress-testing vendor and counterparty lists against updated country-group designations introduced under the Export Control Reform Act framework, with particular pressure on transactions touching Russia, China, and select Middle Eastern jurisdictions.
Watch
- BIS Entity List additions affecting power generation and grid equipment suppliers
- EAR99 reclassification risk for LNG heat exchanger and turbine components
- De minimis threshold rules applied to foreign-origin energy technology re-exports
- OFAC secondary sanctions exposure on commodity trading counterparties in restricted jurisdictions
Recent material activity in Energy, Power & Commodities
Active monitoring in place across Energy, Power & Commodities. Material developments related to export administration regulations compliance will appear here as they are published.