BIS publishes rules regarding CIV and APR license exceptions and military end use and military end user controls for China, Russia and Venezuela

Three important regulatory developments were published yesterday in the Federal Register by the Commerce Department’s Bureau of Industry and Security.

  • A Final Rule eliminating the Civil End Users (CIV) license exception. The Final Rule goes into effect 29 June 2020.

  • A Final Rule expanding license requirements for exports, reexports and in-country transfer for military end use or military end users in China, Russia and Venezuela. The Final Rule goes into effect on 29 June 2020.

  • A Proposed Rule modifying the Additional Permissive Reexports (APR) license exception to remove provisions that authorize reexports of certain national security-controlled items on the Commerce Control List. Comments on the Proposed Rule are due 29 June 2020.

If you have any questions, please reach out to Ajay Kuntamukkala, Stephen Propst, or Adam Berry.


Authored by Ajay Kuntamukkala, Stephen Propst, Adam Berry and Andrea Fraser-Reid

Ajay Kuntamukkala
Washington, D.C.
Stephen Propst
Washington, D.C.
Adam Berry
Senior Associate
Washington D.C.


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