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Changes to the Revolving Door: Trump’s Ethics Executive Order

Client Alert | less than 1 min read | 01.30.17

On January 28, 2017, President Trump issued an executive order setting forth the ethics restrictions for its executive agency appointees. These restrictions, discussed more fully in our blog post, are simultaneously more restrictive and less restrictive than their 2009 Obama counterparts, and appear to be more focused on appointees’ conduct following their exit from Government rather than on their conduct preceding and during their appointments.

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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....