Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

On June 17, 2026, BIS announced a $36,184,680 civil penalty settlement with Robert Bosch GmbH (Stuttgart, Germany) — the largest-ever BIS enforcement penalty against a non-US company for Foreign Direct Product Rule (FDPR) violations. Between September 16, 2020 and September 26, 2024, Bosch exported approximately $72.4 million in MEMS sensor products and automotive software from abroad to Huawei Technologies and its Entity List affiliates without the required BIS license. Bosch filed a Voluntary Self-Disclosure and cooperated throughout; the DOJ issued the first-ever NSD declination under its newly established Corporate Enforcement Policy, declining criminal prosecution entirely.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 16 entities to the Entity List under the destinations of China (14) and Singapore (2). The additions concentrate on the Sophgo Technologies cluster and a set of affiliated PRC fabless / system houses (Suanze, Suanxin, Suanhu, Suanli, Suanneng, Sophon, Quliang, Shunhua) plus two Singapore entities (Sophgo Technologies Pte. Ltd., PowerAir Pte. Ltd.) acting as offshore extensions of the same group. BIS cites involvement in "supporting or directly contributing to the development of advanced computing integrated circuits" that further PRC advanced-weapons, WMD, and high-tech surveillance programs. License requirement covers all items subject to the EAR with a presumption-of-denial review policy. The rule was effective on publication, January 16, 2025.

BIS (acting through its Office of Information and Communications Technology and Services, OICTS) published a final rule under Executive Order 13873's ICTS authority prohibiting certain connected-vehicle (CV) transactions involving hardware and software designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction of the People's Republic of China or the Russian Federation. The rule reaches the Vehicle Connectivity System (VCS — hardware/software enabling external RF connectivity above 450 MHz) and the Automated Driving System (ADS) software stack. Effective 17 March 2025, with phased prohibitions: import/sale of CVs incorporating covered software prohibited from model year 2027; import of covered VCS hardware prohibited from model year 2030 (or 1 January 2029 for hardware not associated with a model year). Importers and connected-vehicle manufacturers must file annual Declarations of Conformity.

On 6 September 2024 the Dutch government announced an expansion of its national export-control measure on advanced semiconductor manufacturing equipment, bringing two additional ASML DUV immersion lithography systems — TWINSCAN NXT:1970i and NXT:1980i — under a Dutch national authorisation requirement for shipments to destinations outside the EU. The measure took effect on 7 September 2024 via a ministerial regulation published in Staatscourant 2024 no. 29008. Until this point those two older system variants were controlled extraterritorially through the US Foreign Direct Product Rule; the change transfers licensing authority from BIS to the Dutch government and aligns the Dutch national list more tightly with the perimeter set by the June-2023 measure on NXT:2000i+. ASML characterised the update as a "technical change" with no expected impact on its 2024 financials or longer-term outlook.

The Bureau of Industry and Security (BIS) issued an interim final rule (FR Doc. 2024-15810) amending the Export Administration Regulations (EAR) so that certain "releases" of technology and software during "standards-related activities" are no longer subject to the EAR. The rule revises 15 CFR §734.10 and consolidates the patchwork of prior carve-outs (May 2019 Huawei 5G TGL, June 2020 IFR, September 2022 Entity-List-wide IFR) into a single activity-based exclusion. The change enables US firms to participate in international standards bodies (IEEE, 3GPP, ITU, ISO, IEC) alongside Entity-Listed parties — most consequentially Huawei — without licence exposure. Comments were due September 16, 2024.

The US Bureau of Industry and Security issued an interim final rule on 17 October 2023 that substantially expanded the advanced-computing and semiconductor manufacturing controls first imposed in October 2022. The rule closed the performance-threshold workaround that NVIDIA had used to ship China-specific A800/H800 GPUs, replacing it with a "performance density" metric and adding a new "Notified Advanced Computing" licence category. It expanded controls on chipmaking equipment (additional ECCNs covering deposition, etch, metrology), pulled 21 additional countries (mostly Middle East / Central Asia) into a regional licensing scheme to prevent transshipment, and added 13 Chinese entities to the Entity List including AI-chip designers.

The Dutch government announced on 30 June 2023 a new national export-licensing requirement covering specific advanced semiconductor manufacturing equipment, most prominently ASML's TWINSCAN NXT:2000i and subsequent DUV immersion lithography systems used at ≤14/16nm logic, advanced DRAM, and advanced 3D NAND production. Effective from 1 September 2023 via the national Strategic Goods Decree, the rule completes the trilateral US-Japan-Netherlands chip-equipment perimeter initiated by the January 2023 trilateral agreement. Although nominally country-neutral, the BIS Foreign Direct Product Rule means licences for shipments to "countries of concern" — read: China — face a presumption of denial. Subsequent guidance in 2024 expanded coverage to additional TWINSCAN NXT:1970Ci and 1980Di system variants.

The Bureau of Industry and Security (BIS) issued an interim final rule (IFR, 87 FR 55241, FR Doc. 2022-19415) amending the Export Administration Regulations (EAR) to authorize the release of specified items to all entities on the Entity List without a licence when such release occurs in the context of a "standards-related activity." The IFR expanded a narrower June 2020 predecessor that had applied only to Huawei and its affiliates; this 2022 rule extended equivalent authorization to the full Entity List. Authorized items include EAR99 technology and software, items controlled solely for anti-terrorism (AT) reasons, and certain cryptographic technology (ECCNs 5D002 and 5E002) used in standards development. The rule amended 15 CFR §§ 734.10, 744.11, 744.16, and Part 772 and was superseded by a broader 2024 IFR that recasted the carve-out as an activity-based exclusion from EAR jurisdiction entirely.

BIS published a technical correction to the Entity List (15 CFR Part 744, Supplement No. 4) fixing three errors in the February 14, 2022 final rule (87 FR 8180; FR Doc. 2022-03029) that added and revised Huawei entities. Two entries — Huawei Cloud Brazil (São Paulo) and Huawei Technologies Co., Ltd. (China, with 22+ affiliated addresses) — incorrectly cited §736.2(b)(3)(vi) as the Foreign Direct Product rule trigger instead of the correct §734.9(e) (the Huawei-specific FDP rule); a third error was a typographical fix to the footnote reference ("except for" → "EXCEPT\2\ for"). No new restrictions were created; the substantive export control status of all listed Huawei entities is unchanged, but exporters relying on the CFR text now have the correct regulatory citation for license requirement determinations.

OFAC codified the Chinese Military-Industrial Complex Sanctions Regulations at 31 CFR Part 586, implementing Executive Order 13959 (November 12, 2020) as amended by Executive Order 14032 (June 3, 2021). The regulations prohibit US persons from purchasing or selling publicly traded securities of entities designated on OFAC's Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, which identifies firms determined to support the People's Liberation Army or Chinese surveillance-technology programs. A divestment deadline of June 3, 2022 applied to entities named in the original EO 13959 annexes; future additions carry a one-year divestment window from the date of designation.

Effective 3 February 2022, the Bureau of Industry and Security published a final rule (87 FR 6231, FR Doc 2022-02302) consolidating all existing Foreign Direct Product (FDP) rules from scattered locations in EAR Parts 736 and 744 into a single new section, 15 CFR §734.9, under Part 734 (Scope of the EAR). The rule made no substantive changes to existing controls — it reorganised four pre-existing FDP rules (National Security, 9x515, 600 Series, and Entity List) into a clean §734.9(b)–(e) architecture, clarified the definition of "major component" at §734.9(a), and corrected a drafting ambiguity that had obscured the U.S.-origin technology trigger for three of the four rules. The newly created §734.9 structure became the vehicle used by BIS to add the Russia/Belarus FDP rule (§734.9(f)) just 21 days later, on 24 February 2022.

The US Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 37 entities under 40 entries to the Entity List, effective December 17, 2021. The additions span three distinct threat rationales: (1) support for Chinese military modernization across semiconductors, submarine cables, armored vehicles, and defense electronics; (2) the Academy of Military Medical Sciences and 11 affiliated institutes pursuing biotechnology processes for military end uses, including purported brain-control weaponry under EAR §744.11(b); and (3) a cross-border Iran sanctions-evasion network operating across China, Georgia, Malaysia, and Turkey that diverted US-origin items to Iran's defense industries and advanced conventional weapons programs. All 40 entries carry a presumption-of-denial licensing policy for all items subject to the EAR, with no license exceptions available.

Effective 17 August 2020 (published in the Federal Register 20 August 2020, Vol. 85 No. 162, FR Doc 2020-18213), BIS implemented three simultaneous measures targeting Huawei's global supply chain. First, 38 non-U.S. affiliates of Huawei Technologies Co., Ltd. were added to the Entity List with the most restrictive license review policy (presumption of denial) and designated under footnote 1, extending the Huawei-specific Foreign-Produced Direct Product Rule (FDPR) to their operations. Second, the Temporary General License (TGL), which since May 2019 had authorized limited ongoing transactions with Huawei (network maintenance, software updates, standards participation), was allowed to expire on 13 August 2020 and replaced with a narrower authorization. Third, BIS expanded the scope of the Huawei FDPR (General Prohibition Three) to cover foreign-produced items when a footnote 1 entity is a party to any transaction or when the item will be used in the production or development of products for any footnote 1 entity, closing the design-house loophole that had allowed TSMC to supply HiSilicon/Kirin chips as long as Huawei was not the direct importer.