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BIS Issues Final Rule on China Exports

Client Alert | 1 min read | 06.18.07

In publishing its long-awaited rule imposing controls on exports to the PRC, BIS has imposed controls where the exporter "knows" of a military end use for 31 categories (down from 47) of items on the Commerce Control List, and created a new authorization for some exports to China that would require a license unless destined to Validated End Users ("VEUs"). In response to extensive public comments, BIS has modified the standard for evaluating "military end use," raised the dollar value of transactions requiring a PRC "End User Statement" (from $5,000 to $50,000), and set out the specific requirements for VEU status, including the specific information required to support an application and the creation of a new inter-agency "End User Review Committee" (including State, Defense, Energy, and others) which must unanimously approve all applications for VEU status. BIS has heralded the VEU, or "trusted customer," approach as a model for the future of export controls in an increasingly list-based compliance environment; this future will depend on the degree of practical usefulness of the VEU model as an alternative to traditional export licenses. The text of the Final Rule is available at http://www.bis.doc.gov/News/2007/Rule%20text.pdf.

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Client Alert | 4 min read | 08.14.26

License to Hack? The White House Greenlights Private-Sector Offensive Cyber Operations

On August 12, 2026, the White House released a National Security Presidential Memorandum (NSPM) making a seismic shift in U.S. cybersecurity policy and establishing a framework to authorize private-sector companies to conduct offensive cyber operations — historically strictly prohibited by federal law — against foreign Cyber-Enabled Transnational Criminal Organizations (CE-TCO). It builds on an executive order issued in March 2026 that directed federal agencies to develop plans to combat cybercrimes against Americans....