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Go Ahead and Offer the Senator a Cup of Coffee

Client Alert | less than 1 min read | 02.21.08

As detailed in the attached bullet analysis, the Senate Select Committee on Ethics, in response to the Honest Leadership and Open Government Act of 2007 (“HLOGA”), published new guidance concerning the gift exceptions for items of little intrinsic value and food offered other than as part of a meal. Although the Senate clarifications arguably clear up very little, they are a good reminder that it is time to update company codes of conduct and compliance manuals in light of the many new requirements established by HLOGA.

Insights

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....