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Articles by Scott Wise
U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows
CM Crowell & Moring LLP More Our founders aspired to create a different kind of law firm when they launched Crowell & Moring in 1979. From those bold beginnings, our mission has been to provide our clients with the best services of any law firm in the world through a spirit of trust, respect, cooperation, collaboration, and a commitment to giving back to the communities around us.
State Department Issues Two New Rules Amending The ITAR
On Friday, September 18, 2026, the U.S. Department of State issued two rules amending the International Traffic in Arms Regulations (ITAR). The first, an interim final rule effective October 19, narrows U.S. Munitions List (USML) Category XX(a) controls on certain uncrewed underwater vehicles. The second, a final rule effective immediately, clarifies policy-of-denial provisions, updates country policies for Ethiopia and Somalia, and adds Saudi Arabia and Peru to the list of major non-NATO allies.
U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows
Key takeaway #1: The U.S.-China trade truce has been extended through January 10, 2027, and the Bureau of Industry and Security’s (BIS’s) suspension of the Affiliates Rule will be extended accordingly.
U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows
Key takeaway #1: The U.S.-China trade truce has been extended through January 10, 2027, and the Bureau of Industry and Security’s (BIS’s) suspension of the Affiliates Rule will be extended accordingly.
BIS Restricts Exports Of “Black Mass,” Tungsten Waste, And Scrap
Scott Wise’s articles from Crowell & Moring LLP are most popular: in United States with readers working within the Healthcare industries Key Takeaways: The Bureau of Industry and Security (“BIS”) issued a temporary final rule under the Defense Priorities and Allocations System (“DPAS”) that restricts exports of shredded lithium-ion battery scrap containing cathode material, known as “black mass,” as well as tungsten and other waste by U.S. entities.
BIS Eases Export Controls On The UAE
Scott Wise’s articles from Crowell & Moring LLP are most popular: with readers working within the Healthcare industries Key Takeaways: The UAE’s reclassification to Country Group A:5 in the U.S. Export Administration Regulations (“EAR”) is one of the most significant expansions of U.S. export licensing flexibility extended to a Middle Eastern partner in recent years.
BIS Eases Export Controls on the UAE
Key Takeaways: The UAE’s reclassification to Country Group A:5 in the U.S. Export Administration Regulations (“EAR”) is one of the most significant expansions of U.S. export licensing flexibility extended to a Middle Eastern partner in recent years. Exporters should promptly assess whether existing licensed shipments or pending BIS applications can now be restructured under a license exception under the EAR.
State Department Proposes ITAR Part 130 Amendments To Reduce Defense Sales Reporting Burden
Scott Wise’s articles from Crowell & Moring LLP are most popular: with readers working within the Banking & Credit and Healthcare industries Key Takeaway: DDTC’s proposed rule would shift ITAR Part 130 reporting from a transaction-linked model to consolidated annual submissions. It also proposes raising monetary thresholds for the first time since 1993.
ATF Catches Up with Export Control Reform (Better Late than Never!)
Key Takeaway: ATF’s latest final rule closes a regulatory gap left by the Export Control Reform (“ECR”) initiative, acknowledging that the Department of Commerce now shares jurisdiction alongside the Department of State over items on ATF’s United States Munitions Import List (“USMIL”). On May 6, 2026, the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”) published a final confirmatory rule updating its regulations to reflect changes stemming from the ECR initiative.
BIS Fines Teledyne FLIR $1 Million For Unlicensed China-Related Thermal Camera Exports And De Minimis Miscalculations
CM Crowell & Moring LLP More Our founders aspired to create a different kind of law firm when they launched Crowell & Moring in 1979. From those bold beginnings, our mission has been to provide our clients with the best services of any law firm in the world through a spirit of trust, respect, cooperation, collaboration, and a commitment to giving back to the communities around us.
House Passes Remote Access Security Act To Limit Adversaries' Remote Access To Critical Technology
CM Crowell & Moring LLP More Our founders aspired to create a different kind of law firm when they launched Crowell & Moring in 1979. From those bold beginnings, our mission has been to provide our clients with the best services of any law firm in the world through a spirit of trust, respect, cooperation, collaboration, and a commitment to giving back to the communities around us.
China Announces New Export Controls Targeting Japan
Scott Wise’s articles from Crowell & Moring LLP are most popular: in United States Crowell & Moring LLP are most popular: within Law Department Performance and Coronavirus (COVID-19) topic(s) On January 6, 2026, China's Ministry of Commerce ("MOFCOM") issued Announcement No. 1 [2026], imposing export controls on dual-use items destined for Japan. The measures took effect immediately, with no wind-down period.
State Department Removes Cambodia From ITAR 126.1 Proscribed Countries List
Scott Wise’s articles from Crowell & Moring LLP are most popular: within International Law topic(s) in United States Crowell & Moring LLP are most popular: within Insurance, Coronavirus (COVID-19) and Accounting and Audit topic(s) The U.S. Department of State ("State") has decided to lift the defense trade embargo against Cambodia.
BIS Adds 26 Entities, Mostly In China, To The Entity List For Supplying Iran With Drone Parts And U.S.-Origin Electronic Items
Scott Wise’s articles from Crowell & Moring LLP are most popular: in United States Crowell & Moring LLP are most popular: within Coronavirus (COVID-19), Insurance and Accounting and Audit topic(s) with readers working within the Environment & Waste Management industries The U.S. Department of Commerce's Bureau of Industry and Security (BIS) published a Final Rule on October 9, 2025 that will add 26 entities and three addresses to the Entity List for a total of 29 new entries (effective...
BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists
In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more by one or more entities listed on BIS’ Entity List, Military End-User (MEU) List, or certain SDN entities.
BIS Issues "Affiliates Rule" To Dramatically Expand Applicability Of Entity And Military End-User Lists
CM Crowell & Moring LLP More Our founders aspired to create a different kind of law firm when they launched Crowell & Moring in 1979. From those bold beginnings, our mission has been to provide our clients with the best services of any law firm in the world through a spirit of trust, respect, cooperation, collaboration, and a commitment to giving back to the communities around us.
BIS Announces Addition Of 32 Entities To The Entity List, Including For Exports To Russia
CM Crowell & Moring LLP More Our founders aspired to create a different kind of law firm when they launched Crowell & Moring in 1979. From those bold beginnings, our mission has been to provide our clients with the best services of any law firm in the world through a spirit of trust, respect, cooperation, collaboration, and a commitment to giving back to the communities around us.
BIS Announces Addition of 32 Entities to the Entity List, Including For Exports to Russia
On September 12, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released a final rule that announced the addition of 32 new entities to the Entity List (see BIS final rule here). 23 entities were added under the destination of China, one under India, one under Iran, one under Singapore, one under Taiwan, three under Turkey, and two under the UAE.
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