Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 25 February 2026 that a U.S. person agreed to pay $3,777,000 to settle potential civil liability for 20 apparent egregious violations of the Syrian Sanctions Regulations (31 CFR Part 542) occurring between January 2018 and December 2021. The individual provided managerial services — reviewing and signing financial statements, approving operational and employee expenses, and supervising service-fee collection — as an officer and board member of four Syrian real-estate companies supporting luxury real-estate development projects in Syria. OFAC determined the conduct was egregious and not voluntarily self-disclosed, setting the settlement at 10× the statutory IEEPA base amount per apparent violation (the maximum egregious multiplier) and establishing a significant personal-liability precedent for U.S. persons serving on boards or in officer roles of companies in sanctioned jurisdictions.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) renamed the Syria-Related Sanctions Regulations (31 CFR Part 569) as the Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations (PAARSS) and amended the renamed regulations to implement the January 15, 2025 Syria-related Executive order (which expanded the national emergency declared in E.O. 13894) and E.O. 14312 of June 30, 2025 ("Providing for the Revocation of Syria Sanctions"). The final rule was effective on publication, 25 September 2025. Substantively, broad Syria-program sanctions are revoked while targeted sanctions remain on Bashar al-Assad and his associates, human rights abusers, Captagon traffickers, persons linked to Syria's past chemical-weapons or other proliferation activities, ISIS and Al-Qa'ida affiliates, and Iran and its proxies operating inside Syria.

On 16 January 2025 the US Bureau of Industry and Security published an interim final rule (90 FR 4598; FR Doc 2025-00723) creating new ECCN 3A069 for high-parameter flow cytometers and liquid chromatography mass spectrometers specially designed for top-down proteomics, plus new ECCN 3E069 for related development and production technology. Items previously controlled under the catch-all ECCN 3A999 are migrated into the dedicated 3A069 classification, which carries National Security (NS), Regional Stability (RS), and Anti-Terrorism (AT) controls. Licensing policy is presumption of denial for destinations in Country Group D:1 and D:5, Macau, and Country Group E (i.e. China, Russia, Iran, North Korea, Cuba, Syria, Venezuela). The rule also adds new EEI/AES filing requirements (§ 758.1(b)(11)) for all 3A069 exports to Country Group D destinations. Public comments were accepted until 17 March 2025.

On 23 December 2024 the US Bureau of Industry and Security published a final rule (89 FR 104408; FR Doc 2024-30425; RIN 0694-AJ83) amending the Export Administration Regulations to implement decisions adopted at the Australia Group's 2023 and 2024 plenary meetings. The rule adds new ECCN 2B352.k controlling instruments for the automated chemical synthesis of peptides that are partly or entirely automated and capable of generating peptides at a system-synthesis scale of 1 mmol or greater, finalising the April 2023 BIS proposed rule. It also adds dipropylamine to ECCN 1C350.d.11, neosaxitoxin to ECCN 1C351.d.12, revises the 1C351.d.3 entry from "botulinum toxins" to "botulinum neurotoxins" to capture all serotypes, adds a "minimum detection limit" definition for toxic-gas monitors in 2B351.a, and explicitly captures single-use centrifugal separators in 2B352.c. License requirements (CB, AT, CW where applicable) apply for export to non-Australia-Group destinations; the rule is effective on publication.

The Bureau of Industry and Security (BIS) added 28 entities under 32 entries to the Entity List effective April 12, 2023, targeting front companies and logistics networks attempting to evade US export controls to acquire US-origin items in support of Russia's military and defense industrial base. Twelve of the entities are Chinese electronics and semiconductor distributors operating as procurement intermediaries; ten are Russian logistics and trading firms; six are spread across Armenia, Malta, Singapore, Spain, Syria, Turkey, UAE, and Uzbekistan as diversion facilitators. All listed entities are subject to a license review policy of denial for virtually all EAR-controlled items.

BIS finalized changes to the Export Administration Regulations (EAR) governing controls on cybersecurity items — primarily intrusion software, command-and-control platforms, and surveillance tools capable of disrupting or monitoring information systems without authorization. The final rule, effective May 26 2022, revises License Exception ACE (Authorized Cybersecurity Exports) originally established by an October 2021 interim rule and narrows end-user carve-outs for government end users in Country Group D:5 and A:6 destinations. Exports of affected ECCNs (4A005, 4D001, 4D004, 4E001, 5A001.j, 5B001, 5D001, 5E001) to Country Groups E:1 and E:2 remain prohibited; D:1 through D:5 government-end-user transactions require a license.

BIS published an interim final rule on October 21, 2021 establishing new Export Control Classification Numbers (ECCNs 4A005, 4D004, 4E001.c, and 5A001.j) for intrusion software systems, command-and-control platforms, and IP network surveillance tools, implementing the Wassenaar Arrangement 2017 cybersecurity decisions into the Export Administration Regulations (EAR). The rule simultaneously created License Exception ACE (Authorized Cybersecurity Exports), codified at § 740.22, to authorize exports to most destinations while imposing licence requirements — or outright prohibitions — for sales to Country Groups E:1/E:2 governments and certain D-group government end-users. Carve-outs for vulnerability disclosure and cyber-incident-response activities were included to protect legitimate security research. The effective date was subsequently delayed from January 19, 2022 to March 7, 2022 by a separate interim rule (FR 2022-00448), and the rule was finalized with revisions on May 26, 2022 (FR 2022-11282).

The Bureau of Industry and Security (BIS) issued an interim final rule on January 15, 2021 substantially expanding the Export Administration Regulations (EAR) Part 744 end-use and end-user control framework to cover military-intelligence entities in China, Cuba, Iran, North Korea, Russia, Syria, and Venezuela. The rule created a new license requirement for exports of ANY EAR-subject item to named military-intelligence end-users — including EAR99-classified items — and separately imposed restrictions on U.S. persons worldwide providing "support" to military-intelligence end-uses or end-users without a BIS licence. It also broadened chemical and biological weapons controls from "will directly assist" to "will support," expanding the reach of §744.4 and §744.3 on WMD-delivery systems. A technical correction published March 17, 2021 (FR Doc 2021-05623) fixed a drafting error in Instruction 9 that would have inadvertently deleted §744.3(a)(3)(i)-(ii), the rocket systems and UAV provisions.