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This final rule implements three simultaneous changes to Cambodia's treatment under the EAR:
1. Country Group D:5 addition — Cambodia was added to Supplement No. 1 to Part 740 (Country Groups), D:5 column. D:5 designation (arms-embargoed destination) triggers license requirements across a wide span of Export Control Classification Numbers (ECCNs) and disqualifies Cambodia from most EAR license exceptions. The BIS action conforms the EAR to a simultaneous State Department final rule amending ITAR §126.1 to add Cambodia as an arms-embargoed destination — both rules sharing the same effective date (December 9, 2021).
2. Military end-use/end-user (MEU) controls — EAR §744.21 — Cambodia was added to the list of countries requiring a license for exports, reexports, or transfers of items identified in Supplement No. 2 to Part 744 when the end use or end user is military. This imposes a policy-of-denial posture for defense-article transactions.
3. Military-intelligence end-use/end-user (MIEU) controls — EAR §744.22 — Cambodia was added to the MIEU-control list, requiring a license when the end user is a military- intelligence organisation.
The rule was issued as a final rule without a prior rulemaking notice period, citing national security and foreign policy grounds that justified immediate effect.
The immediate trigger was documented evidence of Chinese People's Liberation Army Navy (PLAN) construction activity at Cambodia's Ream Naval Base (Sihanoukville province). US intelligence assessments concluded that the construction — which included demolition of two US-funded facilities — was a step toward establishing a permanent PLAN forward-presence installation on the Gulf of Thailand, positioning China to project naval power across the Malacca Strait approaches. The Hun Sen government denied the presence of Chinese military personnel while simultaneously restricting US embassy access to the base.
near-prohibition on dual-use exports to Cambodian defense end-users. Commercial civilian trade was unaffected — Cambodia was not placed on the Entity List and was not subject to foreign-direct product rule restrictions.
limited. The action's significance was political — the first time the US placed Cambodia under an arms embargo, signalling formal alignment of Cambodia with adversary risk.
announcements and effective dates, plus OFAC designation of Cambodian military leaders (announced separately on the same day), indicated a deliberate whole-of-government posture shift rather than a routine regulatory update.
rule (FR Doc 2026-02262), consistent with the Trump-administration Cambodia engagement trajectory. The MEU/MIEU controls under §744.21/§744.22 were retained.
in this register. A wake-discovery pass should consider queuing it as a companion action — this BIS rule is a conforming change and the State rule is the substantive upstream policy decision.
corruption). Those designation actions are not yet in this register.