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Export Practitioner Sept. 2026

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Recent stories
BIS Penalties Rise Toward Statutory Maximums Even as Enforcement Volume Falls
A growing share of Bureau of Industry and Security export-control settlements under the Trump administration have approached the maximum penalties allowed by law, according to a Center for Strategic …
Wire rod on the cooling line
Steel-Producing Economies Adopt Milwaukee Framework to Address Excess Capacity
Members of the Global Forum on Steel Excess Capacity adopted a framework for coordinated action on September 30, targeting market-distorting subsidies, trade circumvention and weaknesses in steel …
Busan Extension Signals Possible Further Delay for BIS Affiliates Rule
The reported extension of the U.S.–China Busan trade agreement until January 10, 2027, could prolong the suspension of the Bureau of Industry and Security’s Affiliates Rule. Whether the extension covers that rule, however, remains unconfirmed in the official materials reviewed.
Palmyra, Syria
U.S. Eases Syria Defense Trade Restrictions; BIS Country-Group Not Yet
The United States has lifted comprehensive economic sanctions on Syria and is easing defense trade restrictions, but export controls remain uneven across agencies. State’s ITAR amendment does not remove Syria from BIS Country Group E:1 or eliminate Syria-specific EAR licensing requirements. Until Commerce acts, businesses must continue to apply those controls alongside targeted Treasury sanctions.
Grand Kremlin Palace, Moscow
Graham Act in place as U.S. and EU Adjust Pressure on Russians
The Graham Act creates immediate compliance risks beyond companies that trade directly with Russia by authorizing tariffs on all goods from major buyers of Russian energy, codifying much of the existing U.S. sanctions regime, and increasing secondary-sanctions exposure for foreign financial institutions. Treasury’s additional Iran-related designation of VTB Bank compounds that banking risk, while the EU’s removal of Alisher Usmanov and Mikhail Fridman—and their continued designation under Latvian and Estonian national sanctions—underscores the need for jurisdiction-specific screening.
State Department
State Proposes USML Reductions, “Specially Designed” Changes, and New Repair Exemption
The State Department’s Directorate of Defense Trade Controls is scheduled to publish a proposed rule on October 1 that would narrow U.S. Munitions List controls, revise key ITAR definitions, and establish a license exemption for temporary exports of foreign defense articles for servicing and repair.

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