Export Administration Regulations compliance
Export Administration Regulations compliance is one of the highest-friction areas in Trade and Geopolitical Risk right now, with the U.S. Department of Commerce Bureau of Industry and Security driving license requirement changes and Entity List additions at a pace that has outrun most firms' internal review cycles. The U.S. Department of the Treasury Office of Foreign Assets Control and the European Commission Directorate-General for Trade have layered their own controls on top of BIS authority, creating overlapping obligations on dual-use goods, technology transfers, and re-export routing that compliance teams are actively reconciling against existing distributor and reseller agreements. The regulatory floor is not stable.
Watch
- BIS Entity List additions affecting semiconductor and advanced computing supply chains
- EAR de minimis rule thresholds under review for foreign-produced direct product determinations
- OFAC secondary sanctions exposure tied to EAR-controlled goods transiting third-country intermediaries
- European Commission dual-use regulation No. 2021/821 implementing measures diverging from U.S. controls
- Deemed export license requirements expanding scope for certain foreign national employee access
Recent material activity in Trade & Geopolitical Risk
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OFAC designates 14 entities linked to Russian defense procurement network
The Treasury Department's Office of Foreign Assets Control added 14 entities and 6 individuals to the Specially Designated Nationals list for their roles in procuring critical technology components for Russia's defense i…
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BIS adds 22 Chinese semiconductor entities to Entity List for advanced chip diversion
The Bureau of Industry and Security expanded export controls targeting Chinese semiconductor entities found to be diverting advanced computing chips through third-country intermediaries. New license requirements affect i…
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