Industrial Policy & Trade Monitor· 2663 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.

On 13 May 2025, two days before the AI Diffusion Rule's primary 15 May 2025 compliance date, the Trump administration's BIS announced it would rescind the Biden-era Framework for AI Diffusion (90 FR 4544) and simultaneously issued three guidance documents that re-routed US AI export policy through existing EAR authorities. The package comprises (1) GP10 guidance asserting that all ECCN 3A090 ICs designed by PRC-headquartered firms are presumptively EAR-violative, with Huawei Ascend 910B/910C/910D processors named explicitly — making US- and non-US-person use, transfer, financing, or servicing of those chips anywhere in the world a presumptive General Prohibition 10 violation; (2) a policy statement warning industry that supplying US advanced computing ICs for training or inference of Chinese AI models risks EAR enforcement; and (3) industry guidance on diversion-prevention diligence. BIS stated a formal Federal Register rescission and replacement rule would follow.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 18 persons to the Unverified List (UVL) and removing 5. Of the 18 additions, 5 are under China, 6 under Finland, 3 under Türkiye, 2 under Kazakhstan, 1 under Italy, and 1 under the United Kingdom — a geographic distribution dominated by Russia-adjacent diversion corridors. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends use of EAR license exceptions for shipments to listed parties and requires US exporters to obtain a UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 25 April 2025 (90 FR 17339).

The US Bureau of Industry and Security (BIS) final rule (89 FR 87261; FR Doc 2024-25411) added 40 entities under 42 entries plus four addresses to the Entity List under the destinations China (11), India (5), Malaysia (2), Russia (13), Singapore (1), and Turkey (14), and modified 52 existing entries across China, Estonia, Finland, India, Turkey, the UAE and the UK. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish, Indian, Malaysian and Singaporean entities listed for transshipping controlled US-origin items to Russian defense end users; the 13 Russia entries cover chemical and biological warfare R&D and defense procurement networks. License requirement is "all items subject to the EAR" with a policy/presumption of denial; four China addresses get the narrower "CCL + EAR99 supp. 7" scope. Effective on publication 2024-11-01.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 8 persons to the Unverified List (UVL) and removing 2. Of the 8 additions, 3 are under China, 2 under Germany, 1 under Pakistan, and 2 under Türkiye. Of the 2 removals, 1 is under Saudi Arabia and 1 under China. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 16 October 2024 (89 FR 83428, FR Doc 2024-23638).

The US Bureau of Industry and Security (BIS) final rule (89 FR 68544; FR Doc 2024-19130) added 123 entities under 131 entries to the Entity List with destinations Russia (63), China (42), Iran (11), Turkey (8), and one each in Canada, Cyprus, Kazakhstan, Kyrgyzstan, Crimea Region of Ukraine, Ukraine, and the United Arab Emirates. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish and other third-country firms (e.g., MAK Logistics, Megatek Ltd., Wellgo International, AllChips Limited, Chipgoo Electronics) named for supplying U.S.-origin electronics and dual-use items to Russian industry and military, plus designation of large numbers of Russian military manufacturers (e.g., JSC 75 Arsenal, FSE Aleksinsky Chemical Plant) as military end users. License requirement is "all items subject to the EAR" with policy/presumption of denial; case-by-case for EAR99 food and medicine to certain Russian military end users. Effective on publication 2024-08-27.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 persons to the Unverified List (UVL) and removing 8. Additions are under five destinations: China (8), Türkiye (2), Cyprus (1), Kyrgyzstan (1), and the United Arab Emirates (1). Removals span China (6), UAE (1) and Russia (1). The single Russian entry (EFO Ltd.) was removed from the UVL because BIS simultaneously moved it to the Entity List, allowing BIS to delete Russia entirely as a UVL destination. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting items subject to the EAR. Published and effective the same day, 3 July 2024 (89 FR 55036, FR Doc 2024-14642).

The US Bureau of Industry and Security (BIS) final rule (89 FR 14385; FR Doc 2024-03969; Docket 240215-0050; RIN 0694-AJ54) added 93 entities under 95 entries to the Entity List, effective 23 February 2024, with destinations Russia (63), Turkey (16), China (8), UAE (4), Kyrgyzstan (2), India (1), and South Korea (1). The dominant rationale is enforcement of Russia-diversion controls: 46 Russian defense manufacturers are designated as military end users acquiring US-origin items for Russia's armed forces, five Chinese entities (including Dennex Enterprises Limited and Shenzhen Speed Industrial Materials Co.) are cited for facilitating diversion of controlled microelectronics to Russia, and 16 Turkish firms are cited as procurement hubs obtaining US-origin items of importance to Russia's war effort. Four UAE entities are designated for transshipment networks serving both Russia and Iran. All entities are subject to a presumption of denial for EAR-controlled items; Russian military end users are additionally subject to the Russia/Belarus FDP rule (15 CFR 734.9(g)).

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 persons to the Unverified List (UVL), all located in the People's Republic of China, on the basis that BIS was unable to verify their bona fides through end-use checks. UVL placement suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting any item subject to the EAR. A grace period applies for items already in transit: shipments commenced before 18 January 2024 may proceed under prior conditions. Published 20 December 2023 (88 FR 87897, FR Doc 2023-27928); effective 19 December 2023.

On 8 December 2023 the Bureau of Industry and Security (BIS) published a direct final rule (88 FR 85479; FR Doc 2023-26532) making two export-liberalisation amendments to the Export Administration Regulations (EAR). First, BIS removes Chemical and Biological Weapons (CB) proliferation column controls from the Commerce Country Chart for exports of certain pathogens and toxins (ECCNs 1C351, 1C353, and 1C354) when destined to Australia Group (AG) member countries, on the basis that AG members operate equivalent domestic CBW-export controls. Second, the rule revises the Crime Control and Detection (CC) column entries for Austria, Finland, Ireland, Liechtenstein, South Korea, Sweden, and Switzerland, reflecting the updated US assessment of those countries' law-enforcement export-control standards. Both changes are effective on publication and reduce US export-licensing burdens for allied-country destinations without altering controls for non-allied markets.

The Bureau of Industry and Security (BIS) added eleven entities across Burma, China, Nicaragua, and Russia to the Entity List, effective March 28, 2023, under a human rights foreign policy rationale. Three Burmese trading companies and two Russian aviation-parts suppliers were designated for selling, procuring, and servicing military equipment enabling the Burmese military regime's attacks on civilians; five Xinjiang-based electronics manufacturers were added for activities contrary to U.S. foreign policy interests; and the Nicaraguan National Police was designated for serious human rights abuses. The rule simultaneously codified in the EAR that protection of human rights worldwide is an explicit basis for Entity List designations — a precedent-setting regulatory amendment extending the existing national-security and foreign-policy framework.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 32 persons across 13 countries to the Unverified List (UVL) on the basis that BIS was unable to verify their bona fides through end-use checks. The largest concentration is in China (14 entities), followed by the UAE (5) and Turkey (4), with single entries in Bulgaria, Canada, Germany, Indonesia, Israel, Malaysia, and Singapore. UVL placement suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement and file Electronic Export Information in the Automated Export System before shipping any item subject to the EAR. Published 24 March 2023 (88 FR 17706, FR Doc 2023-06171); effective 24 March 2023.

The Bureau of Industry and Security added 24 entities across 26 entries to the Entity List, effective December 8, 2022, covering Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates. Three distinct enforcement clusters are addressed: Russian defense-electronics firms and their foreign affiliates supporting Russia's military-industrial base post-Ukraine invasion; Singapore-based front companies that supplied controlled items to PASNA, an Iran-based Specially Designated National; and Pakistani and Emirati entities engaged in unsafeguarded nuclear activities and ballistic-missile proliferation. One entity (Safe Technical Supply Co., LLC) was simultaneously removed from three entries covering Oman, Saudi Arabia, and the UAE.

The Bureau of Industry and Security (BIS) added 31 Chinese entities — including Yangtze Memory Technologies Co., Ltd. (YMTC), China's largest NAND flash manufacturer — to the Unverified List (UVL), suspending license exceptions and requiring end-user statements for all EAR-controlled items destined to these parties. BIS simultaneously removed nine Chinese entities previously on the UVL after successfully completing end-use checks. The rule also established a new 60-day UVL-to-Entity-List escalation clock and clarified that sustained host-government obstruction of end-use checks constitutes independent grounds for Entity List designation — a structural enforcement change aimed at closing China's pattern of blocking BIS post-shipment verification visits.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) on 8 February 2022 to add 33 persons — all based in China — to the Unverified List (UVL) under EAR §744.15(c), on the basis that BIS could not satisfactorily complete end-use checks for these entities for reasons outside US Government control. Placement on the UVL bars exporters from using any EAR license exception when shipping controlled items to listed parties and requires exporters to obtain a certified UVL Statement from the entity or secure a BIS export licence. Sectors represented include semiconductor manufacturing equipment, optoelectronics, UAVs, specialty chemicals, and biotechnology.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to establish new Export Control Classification Numbers (ECCNs) 0A977, 0D977, and 0E977 for water cannon systems designed for riot or crowd control, their software, and related technology. A Commerce Control List licence is now required for exports and reexports to most destinations worldwide, with NATO members and certain other close military allies exempt from the new requirement. The rule furthers US foreign policy interests by enabling human rights-based review of crowd-control equipment transfers globally.

The Export Control Reform Act of 2018 (ECRA, Subtitle B Part I of Pub. L. 115-232, the John S. McCain National Defense Authorization Act for FY2019, signed 13 August 2018 by President Trump, codified at 50 U.S.C. §§ 4801–4852) provides permanent statutory authority for the Export Administration Regulations (EAR), replacing the long-lapsed Export Administration Act of 1979 and resolving a decades-long gap in which the EAR operated on emergency authority alone. ECRA is the foundational parent statute of the modern US dual-use export-control regime: it authorises the Commerce Control List, the Entity List, the Unverified List, the Military End-User (MEU) List, the Foreign Direct Product Rule (FDPR), the emerging-and-foundational technology control framework (§1758), and BIS enforcement and civil/criminal penalty authority — the entire regulatory toolkit under which every BIS-administered export-control action filed in the IPTM register derives its legal authority. ECRA also codified ongoing US participation in the multilateral export-control regimes (Wassenaar, NSG, MTCR, Australia Group) and created the interagency Technology Alert List process.