BIS 50% Beneficiary Rule Suspended
On November 12, 2025, the Department of Commerce, Bureau of Industry and Security, published a rule (90 FR 50857) suspending the previously announced “50% Rule” for the Entity List and Military End User (MEU) List.
Originally scheduled to take effect with the expiration of a General License on November 28, 2025, the rule is now suspended for a year – through November 9, 2026. Given the importance of this rule, companies should continue to work on implementing additional screening and due diligence measures on exporters and suppliers. Keep in mind that restrictions also apply to unlisted parties worldwide and you don’t want to be caught short. Contact us if you want a demo of ECScreening software.
USXports Tracking
The ELISA website that previously provided tracking for pending ITAR applications has been replaced with usxports.gov. The new site is intended to provide a unified case search for applications submitted through DDTC’s DECCS and BIS’s SNAP-R licensing systems. ELISA has been decommissioned, while BIS’s STELA (System for Tracking Export License Applications) remains online.
Cambodia Removed from ITAR § 126.1
Following our previous report that Cambodia would be removed from the ITAR 126.1 list of prohibited destinations, the Department of State, Directorate of Defense Trade Controls (DDTC) published a rule (90 FR 50489, November 7, 2025) officially making that change.
As stated in the rule:
As a result of this change, requests for authorization for transfers of defense articles and defense services to Cambodia will be adjudicated on a case-by-case basis and exemptions that are unavailable for transfers to countries listed in ITAR § 126.1 are now available for transfers to Cambodia, subject to the relevant criteria in the exemption being satisfied.
Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria
On November 10, 2025, the Department of State, Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria. The advisory provides an overview of what business is currently permissible with Syria as well as what sanctions and other restrictions remain in place. While some sanctions on specific persons and entities remain in place, Syria is no longer subject to comprehensive sanctions. Many civilian items (EAR99) may generally be exported without a license, but most Commerce Control List (CCL) items require a license. The advisory (pdf) contains additional detail on the current restrictions and opportunities.