On November 10, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule titled “One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities.” As the title indicates, the final rule formally enacts a one-year suspension of the BIS Affiliates Rule, which had been in effect since September 29, 2025, as we previously reported in “BIS Expands Entity List Controls to All Unlisted Foreign Affiliates Owned 50% or More by Listed Parties.”
China Expands Export Control on Rare Earth Minerals and More
On October 9, 2025, China’s Ministry of Commerce (MOFCOM) announced two new decrees (the “New Rules”) significantly expanding and strengthening export controls over the rare earth supply chain: Decree No. 61 primarily targets foreign-made rare earth metals and products, while Decree No. 62 focuses on the control of rare earth-related technology.
Russia Adopts Fast Track Mechanism for Selling Federal Assets
On September 30, 2025, President Vladimir Putin signed Decree No. 693 “On Certain Particularities of the Sale of Property in Federal Ownership” (here). The measure took effect the moment it was published. The decree is expressly framed as a response to “unfriendly” actions by the United States and its allies. It is adopted “to protect the national interests of the Russian Federation,” citing Federal Laws No. 390 FZ (On Security) and No. 127 FZ on counter measures.
A Discussion on 232 Tariff Revisions
Squire Patton Boggs representatives have recently led several discussions with US Customs and Border Protection (CBP) over the current evolution of Section 232 regulations on aluminum and steel. Based on these conversations and our own evaluation of the landscape, we provide the following summation of the 232 regulatory revisions released on June 3, 2025 and address some concerning rumors and misinterpretations circulating in the trade community.
EU Lifts Key Sanctions on Syria: Legal and Compliance Implications Amid Evolving Opportunities
Earlier this week, the Council of the EU adopted a series of legal instruments giving effect to what had been agreed on 20 May 2025, to significantly reduce sanctions on the Syrian Arab Republic. As a result, all EU economic restrictive measures targeting Syria have been lifted, except for those maintained on specific security-related grounds. This marks a substantial shift in the EU’s sanctions posture, intended to facilitate renewed economic engagement, support post-war reconstruction and encourage institutional re-integration, while preserving targeted measures where legal and strategic considerations continue to apply.
EU Adopts 17th Sanctions Package Against the Russian Federation: Further Targets the “Shadow Fleet” and Expands Export Controls
On 20 May 2025, the European Council announced its 17th sanctions package against the Russian Federation. The latest measures reinforce the EU’s strategic objective of undermining Russia’s capacity to finance and sustain its war efforts in Ukraine.
European Commission Previews New Round of Countermeasures Against the United States
In April 2025, the European Union (“EU”) set tariffs on a series of US imports but immediately suspended their application until 14 July 2025. This was due to the US almost simultaneously announcing that it would be softening its across-the-board tariffs. In the case of EU exports, this meant going from a 20% to a 10% general “reciprocal” tariff for three months to negotiate better US/EU trade arrangements.
Committee on Foreign Investment in the US (CFIUS) “Fast-Track” Pilot Program Being Developed
On May 8, 2025, the US Department of the Treasury (Treasury) announced that it “will establish a fast-track process” to facilitate the review by CFIUS of foreign investment into the US from “allies and partners sources . . . where there is verifiable distance and independence from foreign adversaries or threat actors.” The announcement noted that the contemplated process will include a “Known Investor” portal where information from foreign investors can be collected in advance of investment filings with CFIUS. The process is being developed by Treasury as a pilot program; however, the announcement did not include details for when the process would be rolled out.
In-Person Event: US Export Controls Workshops in the UK – September 15-17, 2025
This hugely successful and highly praised event on US export controls regulations, which is jointly organized by the Export Group for Aerospace, Defence & Dual-Use (EGADD) and Squire Patton Boggs, will be celebrating its 18th Anniversary when it takes place in September 2025.
Recent DCSA Updates Regarding Expansion of FOCI Requirements to Unclassified Government Contracts
The Defense Counterintelligence and Security Agency (DCSA) has provided new updates about the highly anticipated changes that will apply foreign ownership, control or influence (FOCI) mitigation requirements to unclassified contracts.
