Anthony Rapa, Alan G. Kashdan, and Brendan S. Saslow ●
Overview
On July 29, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued proposed rules that would significantly expand controls under the Export Administration Regulations (“EAR”) regarding exports for certain end uses, certain end users, and U.S. person activities.
At a high level, the proposed EAR modifications would (1) add new controlled categories of “military support end users”, “intelligence end users”, and “foreign-security end users”; (2) expand the items and country destinations that would be subject to these end use and end user prohibitions; and (3) modify the Commerce Control List (“CCL”) to add certain surveillance items that can be used to violate human rights. BIS also proposes to modify and expand the controls on activities of U.S. persons in section 744.6 of the EAR to complement the changes proposed to the end-use and end-user controls.
Continue reading “U.S. Department of Commerce Proposes Expanded Export Controls Targeting Military, Intelligence, and Law Enforcement End Users in China and Elsewhere”