EXPORT & SANCTIONS INSIGHTS

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Conceptual image representing the BIS SDN crossover rule in EAR § 744.8, illustrating how end‑user export controls now apply when OFAC‑designated SDNs are parties to transactions involving items subject to the EAR.

BIS Implements SDN Crossover Rule

March 27, 2024

On March 21, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) significantly expanded its end-user restrictions under the Export Administration Regulations (“EAR”), 15 C.F.R. Part 744,…

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