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DPAS Regs Updated and Expanded

Client Alert | less than 1 min read | 08.15.14

On August 14, 2014, Commerce's Bureau of Industry and Security issued a final rule revising the Defense Priorities and Allocations System (DPAS) Regulations. Among other changes, the final rule (1) expands the scope of DPAS coverage by adding homeland security and critical infrastructure protection/restoration activities as reasons that rated orders may be issued; (2) adds language clarifying that recipients of rated orders have delegated authority to place ratings on contracts or orders with lower-tier contractors, subcontractors, and suppliers; and (3) reduces the time for written follow-up if a party is unable to comply with a rated order. 

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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....