The System for Award Management (SAM) has undergone significant changes under the Revolutionary FAR Overhaul (RFO). This RFO initiative is an effort by the Office of Federal Procurement Policy (OFPP), the Federal Acquisition Regulation (FAR) Council, and the General Services Administration (GSA) to support sound procurement for government contracts.  It is being initiated in an

The U.S. Department of Commerce has announced the launching of the American AI Exports Program.  This initiative is part of a larger effort by President Donald Trump to advance the United State’s leadership in advanced technologies.  The program will include hardware, software, applications, models, and  full stack AI export. Full Stack AI refers to a

Export regulations effectiveness in the protection of U.S. national security and promotion of foreign policy objectives has become a growing concern given the pace of regulatory changes.  Recently,  the Foundation for Defense of Democracies and the Center for Strategic and International Studies have published reviews of their findings on the issue. U.S. Semiconductor Controls Center

The AUKUS nuclear submarine program is under a Pentagon review to access if the agreement will leave the U.S. Navy with sufficient submarine fleet assets to address its national security requirements.  There have been concerns that the current agreement would leave the United States with a shortage of Virginia class boats due to challenges in

In an attempt to level the playing field, the Bureau of Industry and Security (BIS) revokes Validated End-User (VEU) waivers that allowed foreign-owned semiconductor facilities in China to import U.S. technology without licenses. Companies such as Samsung and SK Hynix will now be required to obtain licenses for their operations. This move aims to level

Revisions to the International Traffic in Arms Regulations (ITAR) and the United States Munitions List (USML) have been released to streamline compliance and enhance national security while facilitating trade with United States allies.  The Department of State Directorate of Defense Trade Controls (DDTC) has released these changes to clarify the ITAR and remove defense articles

The Bureau of Industry and Security (BIS) has recently paused the processing of new export license applications, leading to significant delays. This pause, which affects applications submitted after February 5, 2025, has raised concerns about the impact on business.  The pause is part of an internal review of licensing policies initiated by Undersecretary Jeffrey Kessler

The US Senate has approved the Export Control Transparency Act in an effort to enhance oversight of the Bureau of Industry and Security (BIS) dual use export controls.  This Act will require the BIS to submit quarterly reports to Congress detailing export licensing requests. This reporting would include aggregate statistics on all license applications and

The Bureau of Industry and Security (BIS) is considering a 50% rule to address loopholes that are being used by subsidiaries of parent organizations on the BIS entity list.  The proposed regulation would be similar to current to regulations enacted by the Office of Foreign Asset Controls (OFAC).  This action would impose licensing requirements across

Self disclosure and cooperation in the investigation of export regulation violations by an entity’s acquiror has led to a waiver of prosecution against the acquiring company (White Deer Management LLC).  The Department of Justice’s National Security Division and the Southern District of Texas’s United States Attorney’s Office have also decided to decline prosecution of the

The International Trade Administration (ITA) has released the 2025 Defense Export Handbook to provide an overview of U.S. trade laws governing the export of defense products.  This handbook also gives guidance to new-to-market exporters on evaluating international markets and includes contact information for export control, trade promotion, and licensing.  The publication describes U.S. statutes that

AUKUS Pillar I and Pillar II ITAR developments continue as the U.S. responds to national security threats with strategic trade controls and security partnerships. In recent news, AUKUS Pillar II has greatly eased the transfer of defense articles and technologies between Australia, the United Kingdom, and the United States. This trilateral security partnership was created

The Bureau of Industry and Security (BIS) has amended the Voluntary Self Disclosure (VSD) process in the Export Administration Regulations (EAR).  The newly released amendment to CFR 15 Section 764.5 and Supplement No. 1 to part 766 provides guidance for settlement determinations of penalties for administrative enforcement cases.  This action evolved from a series of