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Attention Security Managers and FSOs

Client Alert | 1 min read | 07.05.17

The Office of the Director of National Intelligence has issued Security Executive Agency Directive 3, and increased reporting requirements for executive branch employees and contractors with access to classified information or who hold sensitive positions. Among other things, covered individuals must report non-work related foreign travel to their local security office for advance approval and security briefing, and any unplanned day trips into Mexico or Canada must be reported within five days of returning to the U.S. Additionally, the directive requires that all individuals with access to classified information report any continuing association with foreign nationals with whom they share “affection, personal obligation or intimate contact,” as well as any contact with foreign nationals that results in the sharing of personal information.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....

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