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Rhetoric: Yes — Substance: Not Yet

Client Alert | 1 min read | 04.19.17

On April 18, 2017, the president signed an Executive Order taking a modest step towards implementing his Buy American and Hire American campaign promise. With respect to Buy American, the EO directs all agencies to review all domestic preferences applicable to federal procurements or grants (collectively Buy American Laws) and propose policies to ensure maximum use of U.S. manufactured products and components. The Secretary of Commerce is to consolidate the agency findings and recommendations into a report that also assesses the impact that various WTO and Free Trade Agreements have had on buying U.S. made goods, with annual reports to follow. Effective more immediately, any public interest waivers should be made by the head of the agency involved, maximize utilization of domestic products and material, and consider whether any foreign cost advantage is the result of unfair trade practices. Signaling the potential for increased enforcement efforts, the EO requires every agency to "scrupulously monitor, enforce, and comply with Buy American Law." With respect to Hire American, the EO directs DHS, DOL, and other relevant agencies to propose reforms to ensure that H-1B visas are awarded to the most skilled or highest paid petition beneficiaries and that the immigration system is administered to protect the interests of U.S. workers, including through the prevention of fraud and abuse.

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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....