Export Administration Regulations compliance
Export Administration Regulations compliance is one of the highest-friction areas in Trade and Geopolitical Risk right now, with the U.S. Department of Commerce Bureau of Industry and Security driving license requirement changes and Entity List additions at a pace that has outrun most firms' internal review cycles. The U.S. Department of the Treasury Office of Foreign Assets Control and the European Commission Directorate-General for Trade have layered their own controls on top of BIS authority, creating overlapping obligations on dual-use goods, technology transfers, and re-export routing that compliance teams are actively reconciling against existing distributor and reseller agreements. The regulatory floor is not stable.
Watch
- BIS Entity List additions affecting semiconductor and advanced computing supply chains
- EAR de minimis rule thresholds under review for foreign-produced direct product determinations
- OFAC secondary sanctions exposure tied to EAR-controlled goods transiting third-country intermediaries
- European Commission dual-use regulation No. 2021/821 implementing measures diverging from U.S. controls
- Deemed export license requirements expanding scope for certain foreign national employee access
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to export administration regulations compliance will appear here as they are published.