Megan Mohler

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Megan Mohler

BIS

BIS “Affiliates Rule” Suspended One Year, But No Time to Rest

November 30, 2025

On November 10, 2025, the U.S. Bureau of Industry and Security (“BIS”) delayed the effective date of its new Affiliates Rule for a one-year period, until November 9, 2026, after U.S. and China trade talks. The Affiliates Rule, announced on September 29, 2025, expands export controls under the Export Administration Regulations (“EAR”) to extend to non-listed “affiliates” owned or controlled by listed entities (on the Entity List, the Military End User List “MEU”, or certain sanctioned parties) 50% or more in the aggregate.

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steel and aluminum

New Presidential Proclamations – Section 232 Duties on Certain Steel and Aluminum Products from Mexico

August 12, 2024

On July 10, 2024, the President issued two Presidential Proclamations related to the imposition of Section 232 duties on certain steel and aluminum products from Mexico. The first establishes a “melt and pour” requirement for imports of steel articles that are products of Mexico and will increase the section 232 duty rate for imports of steel articles and derivative steel articles that are products of Mexico that are melted and poured in a country other than Mexico, Canada, or the United States.

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BIS

Overview of BIS’s Interim Final Rules, Export Controls for Advanced Computing, Supercomputing, and Artificial Intelligence

November 10, 2023

On October 25, 2023, the Bureau of Industry and Security (“BIS”) published interim final rules amending the Export Administration Regulations (“EAR”) to add/clarify new controls on semiconductor manufacturing equipment (“SME”), advanced computing integrated circuits (“IC”), and computer commodities containing them.

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Prior Disclosure

2022: Prior Disclosure Woes

February 8, 2022

The year is 2022, and companies are turning over a new leaf, making a concerted effort to become compliant with U.S. Customs laws and practices. Seemingly, there are no downsides to conducting a comprehensive Customs compliance review and submitting a Prior Disclosure under 19 U.S.C. § 1592(c)(4) and 19 C.F.R. § 162.74.

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hong kong import export uncertainty

A Harried Hong Kong Make for Import/Export Uncertainty

August 5, 2020

On July 14, 2020, President Trump issued an executive order (EO) that stripped Hong Kong of its different and preferential treatment from mainland People’s Republic of China (PRC or China). In accordance with the 1984 Sino-British Joint Declaration, the city of Hong Kong’s sovereignty was handed over to mainland China from the U.K. in 1997, but as an autonomous city with a largely separate legal and economic system from mainland China.

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