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Export Compliance and List Administration

Client Alert | 1 min read | 09.19.07

Confirmation came this week that BIS is moving ahead with its expanded Entities List proposal which means that exporters will continue to face increasingly difficult list management issues. The proposed rule would allow BIS to identify entities that it reasonably believes pose a risk of being involved in activities that are contrary to the national security or foreign policy interests of the U.S. effectively expanding the criteria used to restrict exports to foreign entities. This effort reflects the ongoing expansion of list-based controls employed by export agencies. Managing the impact of these lists goes well beyond order processing to the full range of international business, including joint research, outsourcing, joint ventures, and many other collaborative efforts driven by globalization. 

For assistance with list-based export control compliance, please contact Jeff Snyder at jsnyder@crowell.com in our Washington, D.C. office.

Events

  • Crowell & Moring hosts the latest in its Globalization programs in California on October 4. For more information and to sign up, follow this link: http://www.crowell.com/events/global/

  • Jeff Snyder will lead panel discussions on ethics and export controls training at programs in Los Angeles on October 24, in New York on October 30, and Miami on November 14. To view the program brochure and for further information, please go to http://www.crowell.com/NewsEvents/Event.aspx?id=284. 

Insights

Client Alert | 4 min read | 09.16.26

CMS Offers Guidance as Scrutiny Rises Over ABA Therapy in Medicaid

Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy. In 2025, Medicaid spent about $10 billion on ABA and related therapy services for children with ASD — a dramatic increase from the $2 billion spent in 2021. ...