Industrial Policy & Trade Monitor· 2668 actions· ✨ 89 recent

The US Department of War announced an USD 18.5 million Defense Production Act (DPA) Title III investment in Lattice Materials (Bozeman, Montana) to expand its capacity to produce optical-grade germanium and silicon crystals and to establish a new capability to recover germanium metal from recycled scrap. The award, funded from the Additional Ukraine Supplemental Appropriations Act of 2022, was approved on 26 September 2025 but public announcement was delayed to 22 December 2025 by the federal government shutdown. Lattice is a leading US manufacturer of germanium and silicon infrared optical lenses, windows and mirrors used in defense surveillance, reconnaissance and targeting systems.

On 22 December 2025 the FCC's Public Safety and Homeland Security Bureau released Public Notice DA-25-1086, adding to the Covered List (under section 1709 of the FY2025 NDAA) all unmanned aircraft systems (UAS) and UAS critical components produced in a foreign country, plus communications and video-surveillance equipment/services produced by DJI Technologies and Autel Robotics (and their subsidiaries, affiliates, and licensing/JV partners). The designation is comprehensive by scope — every foreign-made drone from consumer quadcopters to large uncrewed systems, with no size/performance carve-out — and blocks the FCC from granting any new equipment authorization to covered UAS/components going forward. Previously authorized models already in the US market are not revoked. A follow-on Public Notice (DA-26-22, 7 January 2026) narrowed the scope with a temporary exemption (see amendments).

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.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 entities under 13 entries to the Entity List, listed under the destinations of Burma (1), China (11), and Pakistan (1). The PRC additions concentrate on the optics/photonics, RF/microwave, and military-civil-fusion research-institute layer of China's military-modernization stack — including CAS Changchun Institute of Optics, Fine Mechanics and Physics (CIOMP), Shanghai Institute of Optics and Fine Mechanics (SIOM), Peng Cheng Laboratory, Ji Hua Laboratory, and the Yaguang/Chengdu RML defense-electronics cluster — with explicit references to support for hypersonic-weapons development. The Burma entity is Telecom International Myanmar (Mytel), added for providing surveillance services and financial support to the post-coup military regime; the Pakistan entity (Emerging Future Solutions Pvt Ltd) was added for contributions to Pakistan's ballistic-missile programme. All 13 entries carry a license requirement for all items subject to the EAR with a presumption-of-denial review policy and no license exceptions. The rule was effective on publication, January 6, 2025, with a savings clause through February 5, 2025 for goods already en route.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations by adding 8 entities to the Entity List under the destinations of Burma (2), China (2), and Russia (4), citing actions contrary to US foreign-policy interests, primarily enabling human-rights violations through aerial attacks on civilians (Burma), Uyghur surveillance (China), and facial-recognition targeting of protesters (Russia). All designated entities require licenses for all items subject to the EAR with a presumption of denial. The rule was effective immediately on publication, December 11, 2024.

Bureau of Industry and Security final rule (89 FR 14403, Doc 2024-03674) adding two entities under seven entries to the Entity List, effective February 27, 2024. Sandvine Incorporated, a Canadian deep packet inspection vendor, is listed across six destinations (Canada, India, Japan, Malaysia, Sweden, UAE) because it supplies DPI technology to the Government of Egypt where it is used for mass web-monitoring and censorship. Chengdu Beizhan Electronics Co., Ltd. is listed under China for acquiring and attempting to acquire U.S.-origin items on behalf of the University of Electronic Science and Technology of China (UESTC), a PLA-affiliated institution already on the Entity List. All items subject to the EAR require a license with a presumption-of-denial review policy for both entities. The rule also revises entries for two existing Chinese entities and removes one UAE entry.

Bureau of Industry and Security final rule (88 FR 46071, Doc 2023-15343) adding four entities to the Entity List effective July 18, 2023. Intellexa S.A. (Greece) and Intellexa Limited (Ireland) — the corporate architecture behind the "Predator" commercial spyware platform — and Cytrox Holdings Zrt. (Hungary) and Cytrox AD (North Macedonia) — the developer of the underlying spyware technology — were listed for "trafficking in cyber exploits used to gain access to information systems, thereby threatening the privacy and security of individuals and organizations worldwide." All items subject to the EAR require a license with a presumption-of-denial review policy for all four entities, effectively cutting off access to US-origin hardware, software, and technology.

BIS published a final rule adding 43 entities under 50 entries to the EAR Entity List and removing one entity (Fiber Optic Solutions, Latvia), effective June 12, 2023. The additions span ten countries — China (31 entities), UAE (5), Pakistan (4), South Africa (3), UK (2), and one each in Kenya, Laos, Malaysia, Singapore, and Thailand — targeting four principal threat clusters: China's military modernization and hypersonic-weapons supply chain, an international network of flight-training academies (TFASA and affiliates) providing Western pilot training to Chinese military personnel, Pakistan-linked procurement for unsafeguarded ballistic-missile programs, and UAE/South Africa-based dual-use diversion networks. All listed entities require a BIS licence, with most subject to a presumption of denial.

The Bureau of Industry and Security (BIS) added 37 entities under 38 entries to the Entity List, effective March 2, 2023, spanning six destinations: China (28), Pakistan (4), Burma (3), Russia (1), Belarus (1), and Taiwan (1). The China tranche — the largest — targets entities supporting the People's Liberation Army's military modernization, including BGI Research and Forensic Genomics International (genomic surveillance/data risk), Inspur Group Co. Ltd. (cloud servers supplied to Chinese military), and Loongson Technology (domestic CPU developer). Three Burmese entities, including the Ministry of Transport and Communications, are designated for providing surveillance equipment enabling the military junta's tracking and targeting of civilians. Pakistani entities Abdul Razaq Asim, Add-On Technology, and Dynamic Engineers are added for contributing to Pakistan's ballistic missile programs; Russian DMT Electronics and Belarusian DMT Trading LLC for export-control evasion. All listed entities are subject to a license requirement for all items subject to the EAR, with the review policy being presumption of denial for the majority of Chinese entries.

The Bureau of Industry and Security (BIS) added 76 Russian entities to the Entity List effective February 24, 2023, spanning three rationale categories: (1) biometric surveillance technology enabling Russian filtration operations in occupied Ukraine; (2) illicit acquisition of U.S.-origin controlled items; and (3) the Russian military-industrial complex encompassing missiles, aviation, shipbuilding, semiconductors, telecom, and defense electronics. All 76 entities are subject to a license requirement for all EAR-subject items with a presumption of denial; 66 entities receive footnote-3 designation as Russian military end-users, subjecting them to the Russia/Belarus Military End-User Foreign Direct Product Rule under §734.9(g). Four existing Entity List entries were simultaneously revised with additional aliases and tightened to a policy of denial. Notable designations include KAMAZ, the Skolkovo Foundation, Skoltech, Ilyushin Aviation Complex, and the State Missile Center Named After Akademika V.P. Makeyev.

The US Bureau of Industry and Security (BIS) final rule (88 FR 9380; FR Doc 2023-03193), effective February 10, 2023, added six Chinese entities to the Entity List for supporting China's military modernisation, specifically the People's Liberation Army's (PLA) aerospace programs including airships, high-altitude balloons, and related components. The rule imposed a licence requirement of "all items subject to the EAR" with a review policy of presumption of denial and no licence exceptions available. The action directly followed the PRC high-altitude balloon (HAB) incursion into US airspace in late January–early February 2023 and was one of the first regulatory responses in the balloon-surveillance episode.

The Bureau of Industry and Security added 36 entities — 35 in China, 1 in Japan — to the Entity List under a presumption of denial for all EAR-controlled items, effective December 16, 2022. The most consequential additions are Yangtze Memory Technologies (YMTC, simultaneously removed from the Unverified List), eight Cambricon AI-chip subsidiaries, and Shanghai Micro Electronics Equipment (SMEE), China's sole domestic lithography producer. Three existing entries were revised: CETC 13 and two affiliates gained a Footnote 3 Russian-military-end-user designation, bringing them under the Russia/Belarus Foreign Direct Product rule with a blanket denial policy.

The U.S. Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 36 entities under 41 entries to the Entity List, effective June 28, 2022. The entities — located across China, Lithuania, Pakistan, Russia, Singapore, the UAE, the United Kingdom, Uzbekistan, and Vietnam — were designated for acting contrary to U.S. national security or foreign policy interests. Key grounds include support for China's military modernization and AI-enabled surveillance programs, Pakistan-based proliferation concerns, and supply-chain facilitation for Russia amid the Ukraine invasion. The rule also revised eleven existing entries (Belarus, China, Russia, Slovakia) and corrected one entry (Pakistan).

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.

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.

BIS published an interim rule on January 12, 2022 delaying the effective date of its October 21, 2021 cybersecurity items interim final rule by 45 days, from January 19, 2022 to March 7, 2022. The underlying October 2021 rule establishes new Export Control Classification Numbers (ECCNs) for cybersecurity items — including intrusion software, command-and-control platforms, and surveillance tools — and introduces License Exception ACE (Authorized Cybersecurity Exports) for national security and anti-terrorism purposes. The delay was granted after twelve public comments highlighted significant compliance challenges, with BIS acknowledging the need for additional time for industry to update procedures and for BIS to issue supplemental guidance before the controls took effect.

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.

On November 4, 2021, BIS added four entities to the Entity List under a policy of denial: NSO Group and Candiru (Israel), Positive Technologies (Russia), and Computer Security Initiative Consultancy PTE (Singapore). NSO Group and Candiru were designated for supplying commercial spyware to foreign governments used to maliciously surveil government officials, journalists, activists, and academics; Positive Technologies and CSIC for trafficking cyber tools enabling unauthorized access to information systems. All four entities now require BIS licenses for any export, re-export, or in-country transfer of EAR-controlled items, with a presumption of denial.

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 amended the Export Administration Regulations by adding 34 entities under 43 entries to the Entity List, effective July 12, 2021. The largest cluster — 14 Chinese entities — comprises suppliers of surveillance infrastructure enabling the Chinese government's human-rights abuses in Xinjiang, including video analytics firms, network equipment makers, and geolocation platforms deployed in the Uyghur Region. Six Russian individuals and entities were added for participation in military procurement networks acquiring US-origin electronics and components in violation of the EAR. Additional listings cover Iran sanctions evaders (Canada, Lebanon), a UAE-based nuclear-proliferation facilitator, and one entity elevated from the Unverified List to the Entity List under China. All items subject to the EAR require a BIS licence to export, re-export, or transfer in-country to the listed parties, with a presumption-of-denial review policy.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) on April 9, 2021 to extend military-intelligence end-use and end-user controls to Burma (Myanmar) and to apply U.S.-person activity prohibitions to Burma's military-intelligence entities — specifically the Office of Chief of Military Security Affairs (OCMSA) and the Directorate of Signal. The rule also corrected technical errors introduced by BIS's January 15, 2021 interim final rule (FR Doc 2021-01879), which had originally established the military-intelligence end-use and end-user control framework covering China, Cuba, Iran, North Korea, Russia, Syria, and Venezuela. The addition of Burma responded directly to the February 1, 2021 SAC military coup and the Burmese military's use of surveillance technology to oppress civil society, restrict internet access, and imprison protesters.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to revise the licensing review policy for items controlled for Crime Control (CC) reasons, explicitly embedding human rights considerations into the review calculus. License applications for CC-controlled items — including stun guns, less-lethal ammunition, restraints, and biometric equipment such as fingerprint analyzers, polygraphs, and voice-stress devices — will be assessed case-by-case, with presumption of denial when the destination country or region exhibits civil disorder or when there is a risk items will be used to violate or abuse human rights (through censorship, surveillance, detention, or excessive force). The rule also extended human rights review as a factor to nearly all other EAR license applications, not only CC-flagged items.

BIS published an interim final rule on 5 October 2020 implementing multilateral export controls on six emerging technology categories agreed at the December 2019 Wassenaar Arrangement Plenary meeting, revising Commerce Control List ECCNs 2B001, 3D003, 3E004, 5A004, 5D001, and 9A004. The six technologies are: hybrid additive-manufacturing/CNC machine tools; computational lithography software for extreme-ultraviolet (EUV) mask fabrication; wafer-finishing technology for 5 nm-node production; digital forensics tools that circumvent device authentication to extract raw data; software for monitoring and analysis of communications acquired from a handover interface; and sub-orbital craft. As the first of two US implementing actions for the 2019 Wassenaar Plenary, this rule elevated nascent commercial technologies into permanent CCL classifications enforceable against all non-EAR99 destinations.