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

The US Bureau of Industry and Security modified the existing Entity List entry for Private Military Company 'Wagner' (Russia) by adding Footnote 3, formally designating it as a Russian military end user under 15 CFR § 744.21. Two new aliases and one new Saint Petersburg address were also added, bringing total aliases to five. The existing policy of denial for all EAR-controlled items applies globally — to any export, reexport, or in-country transfer to Wagner wherever located worldwide — with a narrow case-by-case review carve-out for EAR99 food and medicine.

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.

On 16 December 2022 the Council of the European Union adopted Council Regulation (EU) 2022/2474, the 9th package of restrictive measures against Russia, amending Regulation (EU) 833/2014. It entered into force on publication the following day (17 December 2022). The package extends the prohibition on new EU investment from the Russian energy sector to the Russian mining and quarrying sector, bans exports of aircraft and drone engines and their parts to Russia (and to any third country that could re-supply drones to Russia), adds 168 entities to the sectoral export- control annex covering chemicals, nerve agents, night-vision and radio- navigation equipment, electronics and IT components, and prohibits EU advertising, market-research, product-testing and technical-inspection services to Russia. A parallel Council Decision/Implementing Regulation designated a further 141 individuals and 49 entities to the EU asset-freeze and travel-ban list.

Framework Law n° 03-22 forming Morocco's Investment Charter, promulgated by Dahir n° 1-22-76 of 14 joumada I 1444 (9 December 2022) and published in Bulletin Officiel n° 7152 (12 December 2022), replaces the 1995 Investment Charter (Law 18-95) — the first major overhaul of Morocco's horizontal investment-incentive regime in nearly 30 years. Operationalised by Decree n° 2.23.1 (Government Council 26 January 2023, BO publication February 2023), the regime layers a "main" support mechanism (CAPEX subsidies up to 30% combining sector-priority, regional/territorial, gender, sustainable and value-chain bonuses) and a "specific" mechanism for strategic projects ≥ MAD 2bn (~USD 200m) covering EV/batteries, semiconductors, green hydrogen, defence and pharmaceuticals — providing the legal foundation for Morocco's emergence as Africa's leading EV-battery and automotive industrial hub.

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.

Belgium's first horizontal foreign-direct-investment screening regime, established by a Cooperation Agreement signed on 30 November 2022 between the Federal State and the Flemish, Walloon, Brussels-Capital and German-Community governments, and in force from 1 July 2023. The agreement creates a centralised Interfederal Screening Commission (ISC), chaired by the FPS Economy, to receive and process mandatory ex-ante notifications of foreign acquisitions of 10%, 25% or higher voting-rights / control thresholds (sector-dependent) in Belgian undertakings active in eleven strategic sectors. ISC decisions are binding; sanctions for failure to notify or for non-compliance with conditions imposed include unwinding of the transaction and administrative fines.

Act No. 497/2022 Coll. on the Screening of Foreign Investments and on amendments to certain acts, adopted by the National Council of the Slovak Republic on 29 November 2022 and promulgated in the Zbierka zákonov on 23 December 2022, established Slovakia's first horizontal ex-ante foreign-direct-investment screening regime. The Act took effect on 1 March 2023, transposing EU Regulation 2019/452 into Slovak law and replacing the prior sector-specific approach under Act No. 45 on critical infrastructure. Screening is administered by the Ministry of the Economy of the Slovak Republic across three procedures (mandatory, voluntary, and ex officio) and covers transactions in defence, dual-use, critical infrastructure, critical raw materials, biotechnology, AI, semiconductors and other emerging technologies. The Ministry can prohibit, condition or unwind non-compliant transactions and impose administrative penalties.

Switzerland's Federal Council amended the Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) to align with the EU's eighth sanctions package, effective 6pm on 23 November 2022. The amendment creates the Swiss legal basis for an oil price-cap mechanism — banning maritime transport to third countries of Russian-origin crude oil and petroleum products unless purchased at or below a price cap to be set later (the G7/EU $60/bbl cap followed on 3 December 2022; see the companion US OFAC determination of 2022-12-05). It also extends import/export restrictions to additional iron and steel products and aerospace goods, bans the provision of IT, engineering, architecture and legal services to the Russian government and Russian companies, bans Swiss nationals from holding board seats at certain Russian state-owned companies, fully bans crypto-asset wallet/account/custody services to Russian persons regardless of value, and adopts an arms embargo against Russia (extended in part to Ukraine for reasons of Swiss neutrality).

On 19 October 2022, the US Treasury's Office of Foreign Assets Control (OFAC) designated Russian national Yury Yuryevich Orekhov, resident in Dubai, UAE, under Executive Order 14024 for operating a network that procured military and sensitive dual-use technology from Western suppliers for Russian end-users. Two entities tied to Orekhov were designated alongside him: NDA Nord-Deutsche Industrieanlagenbau GmbH, based in Hamburg, Germany, and Opus Energy Trading LLC, based in Dubai, UAE. The designation blocks all US property and interests of the designated persons and generally prohibits US persons from transacting with them.

On 6 October 2022 the Council of the European Union adopted Council Regulation (EU) 2022/1904, amending Regulation (EU) No 833/2014, as the EU's eighth package of restrictive measures against Russia. It entered into force 7 October 2022. The regulation's headline measure creates the legal basis for an oil price-cap mechanism: a ban on maritime transport to third countries of Russian-origin crude oil and petroleum products, becoming operational once the Council sets an actual cap level by a separate decision (the G7/EU $60/bbl cap followed on 3 December 2022). The package also expands import bans on steel products (phased through 2024), firearms and ammunition, wood pulp and paper, and certain chemicals, cosmetics and jewellery materials; extends export bans on aviation-sector goods; bans the provision of architectural, engineering, IT-consultancy and legal advisory services to the Russian government and Russian companies; and imposes restrictions on Russian-flagged vessels at the Russian Maritime Register.

The Bureau of Industry and Security added 57 entities under 57 entries to the Entity List, effective September 30, 2022, in direct response to Russia's ongoing invasion of Ukraine and its illegal annexation of Ukrainian regions. Of the 57 entities, 56 are listed under Russia and one (Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard) under the Crimea Region of Ukraine. The additions span aviation repair and overhaul facilities, aerospace R&D institutes, naval propulsion, ballistic-missile producers, advanced-materials and quantum science institutes, and the federal metrology agency; 50 of the 57 receive footnote 3 designations as Russian military end users, subjecting them to the Russia/Belarus-Military End User Foreign Direct Product Rule. All are added with a license review policy of denial for all EAR-subject items except food and medicine designated EAR99.

The Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 15 September 2022, adding new export-control categories covering quantum computing equipment and related technology (new licensing requirements under a near-total policy of denial), discrete chemicals and biologics including fentanyl precursors and CBW-related production equipment (new Supplement No. 6 to Part 746), and 57 EAR99 industrial items added to the industry-sector sanctions list (Supplement No. 4). Six entities were concurrently designated as Russian Military End Users (MEU), and MEU/MIEU licensing restrictions were extended worldwide (previously limited to six countries). The rule also extended the Foreign Direct Product Rule to additional categories of foreign-made items.

The US Department of Defense published a final rule (DFARS Case 2020-D007) in the Federal Register on 25 August 2022, effective the same day, amending the Defense Federal Acquisition Regulation Supplement to implement section 849 of the FY2020 National Defense Authorization Act. The rule prohibits DoD's acquisition of tantalum metals and alloys melted or produced in North Korea, China, Russia or Iran, and of any end item manufactured in one of those countries that contains such tantalum.

The U.S. Bureau of Industry and Security (BIS) added seven Chinese entities — under seven entries — to the Entity List, effective August 24, 2022, for acquiring or attempting to acquire U.S.-origin items in support of China's military modernization efforts. The entities span China's state-owned aerospace, space-technology, electronics, and control-systems research institutes. All seven entries carry a license requirement covering all items subject to the EAR, with a presumption-of-denial review policy.

The Bureau of Industry and Security (BIS) amended the Commerce Control List (CCL) under the Export Administration Regulations (EAR) to implement four emerging and foundational technology decisions agreed at the December 2021 Wassenaar Arrangement Plenary meeting, pursuant to ECRA Section 1758. The rule adds new export controls on ultra-wide bandgap semiconductor substrates (gallium oxide Ga₂O₃ and diamond), ECAD software for Gate-All- Around Field-Effect Transistor (GAAFET) integrated circuit development, and Pressure Gain Combustion (PGC) technology for advanced gas turbine engines. Controls require a licence for items destined to countries listed in the NS:1 and AT:1 columns of the Commerce Country Chart; ECAD software controls (ECCN 3D006) have a delayed compliance date of October 14, 2022.

Bangladesh's Cabinet approved the National Industrial Policy 2022 on 11 August 2022, replacing the National Industrial Policy 2016 as the country's foundational umbrella industrial-policy statute; the Ministry of Industries gazetted it on 29 September 2022. The policy sets a target to raise industry's share of GDP to 40% by 2027 and introduces a sector taxonomy covering export-diversification, special-development (electronics, automotive assembly, semiconductors, renewable energy, defence-electronics), priority, reserved, and controlled categories. CMSMEs (Cottage, Micro, Small, and Medium Enterprises) are designated the "main driving force of industrialisation," with sector-specific concessional finance, tax holidays, and cluster-development frameworks, alongside FDI incentives including Bangladeshi citizenship for investors committing USD 1 million. The policy for the first time formally incorporates Bangladesh's informal sector within a national industrial-policy framework, mandating a National Informal Sector Database and a 2022–2027 implementation action plan.

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).

The Bureau of Industry and Security published a final rule on 6 June 2022 (effective 2 June 2022) consolidating corrections, clarifications, and substantive amendments to the series of EAR Russia/Belarus rules issued between February and May 2022. The most significant substantive change eliminates the EAR99 food and medicine carve-out for 146 footnote-3-designated military end-user entities already on the Entity List, subjecting all items subject to the EAR — including previously exempt food and medicine — to licensing requirements with a policy of denial for the FSB, SVR, and GRU. Additional provisions clarify luxury goods value thresholds, oil refinery sector controls, and civil telecommunications license review policy, and correct cross-references in the Foreign Direct Product Rules for Russia and Belarus.

The US Department of Commerce Bureau of Industry and Security (BIS) added 71 entities — 70 Russian and 1 Belarusian — to the Entity List, effective June 2, 2022, in direct response to Russia's further invasion of Ukraine on February 24, 2022. The entities were designated as military end users acquiring or attempting to acquire US-origin items in support of Russia's military, and are subject to a policy of denial for all items subject to the Export Administration Regulations (EAR). Sixty-six entities receive a "footnote 3" military end-user designation, while five face outright denial with no license exceptions available beyond humanitarian food and medicine.

The Bureau of Industry and Security (BIS) published a final rule (FR Doc 2022-11761) on June 1, 2022 adding a new section (15 CFR § 743.6) to the Export Administration Regulations (EAR) requiring BIS to notify Congress before issuing export licenses for semiautomatic firearms (ECCN 0A501.a) where a single license application meets or exceeds $4 million in value. The notification requirement applies to destinations outside Country Groups A:5 and A:6 (close US allies) and does not apply to exports under License Exception GOV for US government or NATO agency use. The rule is a Biden-era oversight measure adopted under the Export Control Reform Act of 2018 (ECRA); it is a predecessor step in the regulatory arc that culminated in the 2024 BIS Firearms IFR (FR Doc 2024-08813), which was later partially rescinded in 2025.

Canada registered SOR/2022-98, Regulations Amending the Special Economic Measures (Russia) Regulations, on 6 May 2022, adding five Russian defence-sector entities to Schedule 1 of the regulations: Zelenodolsk Shipyard JSC, Military Industrial Company LLC, Rosgvardia, UEC Klimov JSC and KAMAZ PTC. The listing triggers Canada's standard dealing/asset-freeze prohibitions against the named entities under the Special Economic Measures Act, part of Canada's ongoing sanctions response to Russia's February 2022 invasion of Ukraine.

On 2 May 2022 OFAC published a comprehensive final rule in the Federal Register renaming the Ukraine Related Sanctions Regulations (31 CFR Part 589) to the Ukraine-/Russia-Related Sanctions Regulations and replacing the abbreviated regulatory text that had been in place since 2014 with a fully elaborated framework. The new Part 589 incorporates interpretive guidance, definitional provisions, and consolidated general licenses implementing Executive Orders 13660, 13661, and 13662 — the original March 2014 Ukraine/Crimea-crisis authorities. The rule does not introduce new substantive prohibitions; it formalises and makes accessible the regulatory infrastructure that underlies subsequent GL issuances (e.g., GL 13Q/13R, GL 15K/15L) and OFAC designation actions under the Ukraine-/Russia-Related Sanctions program.

The Bureau of Industry and Security (BIS) issued a final rule expanding license requirements under the EAR for all items on the Commerce Control List (CCL) destined for Russia and Belarus, retroactively effective April 8, 2022. The rule also removes certain license exceptions that previously allowed aircraft-related transactions involving Belarus to proceed without authorization. Issued in direct response to Russia's continued aggression in Ukraine and Belarus's role in enabling it, this measure substantially tightens the multilateral export- control perimeter first established by BIS in late February 2022.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 120 entities under 120 entries to the Entity List, effective 1 April 2022 and published in the Federal Register on 7 April 2022. All 120 entities — located in Russia and Belarus — were determined to be acting contrary to US national security or foreign policy interests in the context of Russia's further invasion of Ukraine beginning 24 February 2022. The rule imposes a presumption-of-denial policy for all EAR-subject items and prohibits all license exceptions for exports, reexports, or in-country transfers to the listed parties. Ninety-five of the 120 entities are additionally designated under Footnote 3 of the Entity List as military end users, triggering the Russian/Belarusian Military End User foreign-produced direct product rule (MEU FDP Rule), extending US extraterritorial reach to non-US items made with US-origin technology.

Canada amended the Special Economic Measures (Belarus) Regulations via SOR/2022-075, registered and in force 5 April 2022, in response to Belarus's support for Russia's invasion of Ukraine. The amendment prohibits any person in Canada and any Canadian outside Canada from providing insurance, reinsurance or underwriting services for aviation and aerospace products owned, controlled, registered to, chartered by or operated by Belarus or a Belarusian person. A new section 3.6 separately establishes export prohibitions on goods and technologies listed on a Belarus Restricted Goods and Technologies List, incorporated by reference, aligning Canada's Belarus measures with its parallel Russia export-control regime. The same instrument added nine individuals (Belarusian oligarchs and defence officials) to the Schedule 1 asset-freeze list, outside this action's scope.

On 4 April 2022 Australia's Minister for Foreign Affairs registered the Autonomous Sanctions (Export Sanctioned Goods—Russia) Amendment (No.1) Designation 2022, made under the Autonomous Sanctions Regulations 2011. It amended the existing Export Sanctioned Goods—Russia designation to add further categories of goods to the list of items whose export, supply or transfer to Russia is prohibited, extending an export-ban regime introduced in response to Russia's invasion of Ukraine. It took effect on registration.

Canada amended the Special Economic Measures (Russia) Regulations via SOR/2022-067, registered and in force 24 March 2022, establishing a new "Restricted Goods and Technologies List" and prohibiting any person in Canada, and any Canadian outside Canada, from exporting, selling, supplying or shipping any listed good or technology to Russia or to any person in Russia. The list is maintained and published separately by Global Affairs Canada and covers items with dual civilian/military applications across electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation equipment.

The Department of Commerce Bureau of Industry and Security (BIS) added 91 entities (across 96 entries) to the Entity List under 15 CFR Part 744, in direct response to Russia's further invasion of Ukraine on 24 February 2022. The listed entities span ten destinations — Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and the United Kingdom — and include Russian military research institutes, shipbuilding facilities, aerospace and electronics manufacturers, and suspected front companies in third countries used to circumvent EAR controls. A license is required for all items subject to the EAR; the review policy is denial for 86 entities and case-by-case (for US Government-supported space programs) for five.

Regulations Amending the Special Economic Measures (Belarus) Regulations, SOR/2022-49, were registered and came into force on 8 March 2022. They add 19 individuals and 25 entities to Schedule 1 and widen the listing criteria to cover persons supporting the violation of Ukraine's sovereignty or territorial integrity. Listed entities named in the regulatory impact statement include the potash producer Belaruskali OAO and the Belarusian Potash Company, the Naftan Oil Refinery and Belneftkhim, and Absolutbank, Belinvestbank, Belbizneslizing and Bank Dabrabyt. Listing brings asset freezes and dealing prohibitions for persons in Canada.

On 6 March 2022, the South Korean government determined that Belarus had materially supported Russia's invasion of Ukraine and announced it would extend the export-control measures already applied to Russia to Belarus as well. Effective 7 March 2022, Korea designated two Belarusian entities (Belarus's Ministry of Defence and a second entity) to its "parties of concern" list, triggering a case-by-case licensing requirement for strategic items under Korea's multilateral export-control regime, and tightened review of non-strategic dual-use items destined for Belarus.

On 4 March 2022 Switzerland's Federal Council adopted a total revision of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), taking effect the same day at 18:00, to fully implement the EU's sanctions packages of 23 and 25 February 2022. The revision bans export of all dual-use goods to Russia regardless of end use or end user, bans export of goods that could contribute to Russia's military or technological strengthening or its defence and security sector, and prohibits export of specified goods and services to the oil sector, as well as goods for aviation, space and oil-refining/gas-liquefaction use.

Effective 2 March 2022, the US Bureau of Industry and Security (BIS) extended to Belarus the same sweeping EAR sanctions imposed on Russia following Russia's full-scale invasion of Ukraine on 24 February 2022. The rule adds Commerce Control List (CCL)-based license requirements for Belarus with a policy of denial across virtually all categories, extends both the Russia Foreign Direct Product (FDP) rule and the Russia Military End User (MEU) FDP rule to cover Belarus and Belarusian military end users, and aligns Belarus with Russia's license review policy. The action was triggered by Belarus's active enablement of the Russian military operation from its territory.

On 1 March 2022, OFAC published an interim final rule adding the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) at 31 CFR Part 587, codifying into Title 31 of the Code of Federal Regulations all prohibitions previously imposed by Executive Order 14024 of 15 April 2021. The regulations were issued in abbreviated form to provide immediate public guidance, with OFAC indicating an intent to supplement them with additional definitions, general licenses, and interpretive guidance. All transactions prohibited under EO 14024 — including prior sectoral determinations and directives targeting Russia's financial services sector, sovereign debt markets, and key state institutions — are formally prohibited under Part 587, giving domestic courts and compliance teams a stable regulatory anchor.

On 25 February 2022, the day after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014. It prohibits the sale, supply, transfer or export of dual-use goods and technology to any person, entity or body in Russia, or for military use or military end-users there, and extends to goods and technology suited for use in the oil refining industry and for the aviation and space industry, alongside a ban on related technical assistance, brokering, financing and insurance/maintenance services. The Regulation entered into force on the day after its Official Journal publication (OJ L 49, 25.2.2022), i.e. 26 February 2022.

On 24 February 2022, hours after Russia's invasion of Ukraine began, the UK Foreign Secretary announced a full asset freeze on VTB, Russia's second-largest bank (£154bn in assets, 95,000 employees), alongside a freeze on all Russian bank assets in the UK and a ban on Russian companies raising finance on UK markets. The package designated more than 100 companies and individuals -- including five major defence firms (Rostec, Uralvagonzavod, Tactical Missile Corporation, United Aircraft Corporation, United Shipbuilding Corporation) and Putin-inner-circle figures such as Kirill Shamalov -- for asset freezes and travel bans. Aeroflot was banned from UK airspace and new export controls were imposed on electronics, telecommunications and aerospace goods to Russia.

Effective 24 February 2022 — the date of Russia's full-scale invasion of Ukraine — the US Bureau of Industry and Security (BIS) published an interim final rule (87 FR 12226, FR Doc 2022-04300) adding sweeping new export license requirements under a new § 746.8 of the Export Administration Regulations (EAR). The rule requires a licence for any item in CCL Categories 3–9 (electronics, computers, telecommunications, sensors, lasers, navigation/avionics, marine, aerospace, propulsion) exported, reexported, or transferred to Russia, with a review policy of denial. Two new Russia-specific Foreign Direct Product (FDP) rules extend US jurisdiction to foreign-manufactured goods: the Russia FDP Rule (§ 734.9(f)) covers all foreign-made items using US technology/equipment destined for Russia, and the Russia-MEU FDP Rule (§ 734.9(g)) covers items destined to 47 designated military-end-user (MEU) entities with no licence exceptions available. All three restrictions carry a presumption of denial, making this the most sweeping peacetime expansion of the EAR since its modern codification.

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 Bureau of Industry and Security (BIS) extended for a second time the temporary unilateral export control on software classified as ECCN 0D521 — "software specially designed for training a Deep Convolutional Neural Network to automate the analysis of geospatial imagery and point clouds" — adding a third year of control through January 6, 2023. The extension was required because COVID-19 prevented the Wassenaar Arrangement from formally convening in 2020 or holding sufficient deliberations in 2021 to consider the US multilateral control proposal submitted in 2020. Only License Exception GOV (§ 740.11(b)(2)(ii)) is available; all other exports require a specific license from BIS.