New From BIS: Changes to EAR Direct Product Rule to Tighten Supply Chain for Certain Designated Entity List Organizations

A new Interim Final Rule (New Rule) issued by the US Department of Commerce’s Bureau of Industry and Security (BIS), which amended the Export Administration Regulations (EAR) (15 CFR Parts 730-774) by expanding the direct product rule as applied to certain organizations on the Entity List took effect on May 15, 2020. A comment period is open until July 14, 2020. Our publication discusses the purpose of the New Rule, how it captures foreign-made items subject to the EAR, and the rule’s savings clause. Please contact our team collectively here with any questions.