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BIS Enforcement Action Highlights Risks in De Minimis Calculations for Foreign-Made Items
A recent BIS enforcement action against Teledyne FLIR highlights the risks of misapplying the EAR’s de minimis rule in global supply chains. The case underscores the need for accurate valuation, proper classification of U.S.-origin content, and robust documentation to avoid significant export control penalties.
Export Controls & National Security Round Table
Yormick Law is launching a renewed quarterly Export Controls & National Security Roundtable series, featuring lunch-and-learn sessions focused on key regulatory developments, emerging issues, and practical insights for navigating complex compliance requirements.
Court of Appeals Affirms Transaction Value Applies When Sales are Structured as Domestic, if the Sales Trigger Exportation to the US
The U.S. Court of Appeals for the Federal Circuit affirmed that transaction value applies for customs valuation when sales–regardless of being structured as domestic–trigger the exportation of goods to the United States.
Suspensión temporal de la regla de afiliados de BIS
On 1 November 2025, the White House announced that, effective 10 November 2025, BIS will suspend implementation of the Affiliates Rule for one (1) year in connection with recently concluded, broader trade negotiations with China.
El BIS publica la norma 50% para la lista de entidades y la lista de afiliados de la MEU
On September 29, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule implementing a 50% ownership threshold for affiliates of parties on the Entity List and Military End-User (“MEU”) List.
EU Tightens Russia Sanctions and Secures Landmark 15% Trade Deal with US
The European Union has announced two major developments with wide-ranging impacts for companies in the defense, dual-use, and advanced manufacturing sectors: a new round of Russia-focused sanctions and a landmark trade agreement with the United States.