Insights on National Security

International Trade & Investment Counsel Sylvia Costelloe will lead a workshop titled “Connected-Vehicle AI & Data Compliance Lab” on March 9, 2026.

In a January 20 interim final rule, the Bureau of Industry and Security (BIS) eased restrictions on the export, reexport, and transfer (in-country) of certain types of unmanned aerial vehicles (UAVs) to lower risk destinations.

Welcome to the January 2026 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

The past year, global trade upended. Through aggressive use of tariffs under the International Economic Emergency Powers Act (IEEPA), expanded Section 232 investigations, and a sustained enforcement crackdown, the Trump Administration made good on US Trade Representative (USTR) Jamieson Greer’s promise to “remake the global order.” The result: a fundamentally different operating environment for importers.

On January 15, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule revising its license review policy for exports of Nvidia H200 chips and its equivalents to China and Macau.

Last year saw a number of significant developments in US export controls and sanctions.

On January 2, President Trump issued an Executive Order (EO) under Section 721 of the Defense Production Act of 1950 requiring HieFo Corporation to divest the digital chips business of EMCORE Corporation, which it acquired in April 2024, due to national security concerns.

Welcome to the December 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

Welcome to the November 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

It’s hard not to experience whiplash with export controls recently. A little over a month ago, the Bureau of Industry and Security (BIS) announced the new Affiliates Rule, which took effect immediately on September 29.

Welcome to the October 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

The Bureau of Industry and Security (BIS) updated its Entity List FAQs, providing some additional guidance about the “Affiliates Rule” that came into effect on September 29.

On September 29, the Bureau of Industry and Security (BIS) issued an interim final rule that significantly expands end user controls under the Export Administration Regulations (EAR) by extending restrictions to foreign entities owned, directly or indirectly, 50% or more by one or more parties on specified lists of proscribed companies, including the Entity List.

Welcome to the September 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

After a three month wait, the US Department of Commerce’s Bureau of Industry and Security (BIS) has finally caught up with the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) in relaxing restrictions on trade with Syria, but this time in the export control world.

Welcome to the August 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

On July 25, the US Department of Commerce, Bureau of Industry and Security (BIS) issued new Frequently Asked Questions (FAQs) related to the January 16 Information and Communication Technology and Services (ICTS) Rule that prohibits the import and sale of connected vehicles and their related hardware/software with a sufficient Chinese or Russian nexus, “Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles” (the Rule).

The Trump Administration is moving aggressively to prevent foreign adversaries’ ownership of US agricultural land.

The Committee on Foreign Investment in the United States (CFIUS) is back in the spotlight.

Welcome to the July 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

On June 11, the US Department of Commerce, Bureau of Industry and Security (BIS) announced the release of two General Authorizations, accompanied by additional Frequently Asked Questions (FAQs) related to the January 16 Information and Communication Technology and Services (ICTS) Rule that prohibits the import and sale of connected vehicles and their related hardware/software with a sufficient Chinese or Russian nexus, “Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles” (the Connected Vehicles Rule).

Welcome to the June 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

On June 9, Deputy US Attorney General Todd Blanche issued a memorandum outlining new guidelines for the enforcement of the Foreign Corrupt Practices Act (FCPA).

Welcome to the May 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

On April 28, the US Department of Commerce, Bureau of Industry and Security (BIS) published the long anticipated Frequently Asked Questions (FAQs) regarding the January 16 Information and Communication Technology and Services (ICTS) Rule that prohibits the import and sale of connected vehicles and their related hardware/software with a sufficient Chinese or Russian nexus (“Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles.”)