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

In a final rule effective December 9, 2021 (FR Doc 2021-26633), the Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add Cambodia to Country Group D:5 (US arms-embargoed destinations), consistent with a simultaneous Department of State final rule adding Cambodia to ITAR §126.1. The rule also subjects Cambodia to military end-use (MEU) controls under EAR §744.21 and military-intelligence end-use/end-user (MIEU) controls under EAR §744.22. The stated rationale was deepening Chinese military presence at Ream Naval Base, growing corruption, and human-rights abuses by the Cambodian government.

Germany's Lieferkettensorgfaltspflichtengesetz (LkSG), promulgated 16 July 2021 (BGBl. I 2021 S. 2959), requires German-headquartered companies to conduct mandatory human-rights and environmental due diligence across their own operations and direct suppliers (with cause-based obligations extending to indirect suppliers). Enforced by BAFA with administrative fines up to EUR 8 million or 2% of global annual turnover for firms with revenue ≥ EUR 400 million. The act applies to ~3,000 German corporates from 1 January 2023 (≥3,000 employees) and was extended to ~5,000 firms from 1 January 2024 (≥1,000 employees). A September 2025 cabinet amendment removed the annual-reporting obligation and narrowed sanctionable omissions to serious violations.

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.

Regulation (EU) 2021/821, adopted 20 May 2021 and applied from 9 September 2021, establishes the Union regime for controlling exports, brokering, technical assistance, transit, and transfer of dual-use items, repealing Regulation (EC) No 428/2009. Annex I lists controlled items implementing internationally agreed dual-use controls under the Wassenaar Arrangement, MTCR, Australia Group, NSG, and Chemical Weapons Convention. The regulation introduces a new catch-all control on cyber-surveillance technologies that could facilitate human-rights violations (Art. 5 and Annex IV), and strengthens cooperation between Member States and the European Commission, placing specific obligations on exporters. It serves as the statutory anchor for all EU export licences, every multilateral-regime transposition into EU law, and coordination mechanisms with US BIS, UK ECJU, JP METI, and KR MOTIE export-control regimes.