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BIS: More judgment, less guidance

Department of Commerce, Washington, DC
The Bureau of Industry and Security is demanding more sophisticated compliance judgments from exporters while retreating from the education and engagement that help companies make them, according to a recent commentary from CSIS.
The transactions benefited Moscow Machinery Building Plant Avangard, a manufacturer associated with Russia’s S-300 and S-400 air-defense systems.
The case shows how delayed disclosure and unresolved sanctions warnings can turn a modest sales account into a multimillion-dollar enforcement matter. Extreme’s cooperation and remediation secured DOJ’s first “near miss” non-prosecution agreement, but reporting only after a journalist presented new evidence cost it eligibility for a declination.

Commerce Blocks Seoul Export-Control Exception

Senior Commerce Department officials have frozen expansion of a program that rewards foreign governments for adopting export controls comparable to those of the United States, rejecting South Korea and Vietnam despite recommendations from career staff. Officials also halted preliminary discussions with Saudi Arabia. The decisions leave those countries outside a licensing exception for selected quantum-computing, semiconductor, and advanced-manufacturing items.

Treasury Proposes Broader Outbound Investment Controls, Extending Restrictions to Biotechnology

The Treasury Department has proposed expanding restrictions on U.S. investment in sensitive foreign technologies, with consequences for technology companies, private investment funds, multinational businesses and drug developers. The October 22 proposal would broaden existing controls on semiconductors, artificial intelligence and quantum technologies while adding biotechnology, hypersonic systems and additional high-performance computing activities. 

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The Washington Tariff and Trade Letter introduces a web-based format for easier review, research and sharing.  Clicking on a story in the newsletter will now bring you to the full text on our new web site. A .pdf version of the newsletter is available below.   For any questions about website access and your subscription, please contact us at Info@TradeRegs.com – Or call the Editor, Frank Ruffing, at +1.703.283.5220

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Vol 46 No. 45, November 9, 2026

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Nvidia General Counsel Tim Teter invoked permission from Under Secretary Jeffrey Kessler when approaching agents about the inquiry.

Scrutiny of Commerce’s Decision Process in Chip-Diversion Inquiry

Congressional scrutiny of advanced AI chip exports is turning to the integrity of the government’s decision process: who authorized shipments, what intelligence informed those decisions, and whether Nvidia’s access to senior officials affected enforcement.

Block announces tentative $764 million settlement with Justice Department

The CashApp parent accrued $764 million as of September 30 but cautioned that final terms could produce additional losses. The company also reported that SEC staff closed a separate investigation in March 2026 without recommending enforcement action. 
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BAE Systems Controls Settles Antiboycott Reporting Charges

The company discovered the provisions during an internal review after learning that the customer appeared on the Office of Antiboycott Compliance’s March 2024 Requester List. It voluntarily disclosed the requests, cooperated with the investigation, and introduced an automated screening tool.

Treasury targets cryptocurrency exchange

On November 6, 2026, the Financial Crimes Enforcement Network (FinCEN) announced an order prohibiting U.S. financial institutions from transmitting funds to or from MEXC Global, a convertible virtual …

NDAA Returns to Congress With Export Controls, China Restrictions and Investment Security at Stake

Congress returns next week facing negotiations over the FY2027 National Defense Authorization Act, with significant export-control and economic-security provisions awaiting resolution.

WTO Faces Budget Pressure as Unpaid Contributions Constrain Operations

Delayed member contributions are constraining the World Trade Organization’s 2026 operations, prompting scrutiny of spending priorities, financial oversight and a proposed increase in administrative charges for a program supporting least-developed countries.
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CBP’s interim final rule will require foreign importers of record to obtain CTPAT validation or use a CTPAT-validated licensed customs broker for covered formal and informal consumption entries. The rule also narrows eligibility for U.S. importer status, and requires brokers to substantiate clients’ U.S. status.
U.S. Court of International Trade in New York.
The Court of International Trade three judge panel considering a challenge to President Trump’s decision to impose Section 301 tariffs on countries for failure to keep products made with forced labor out of their markets is asking the plaintiffs involved to provide lists of the countries whose products they import.
The extension confirms that the Affiliates Rule suspension will continue through January 10, resolving uncertainty over whether it was covered by the extended U.S.–China trade truce. Companies gain two months to strengthen ownership screening and due diligence, but the underlying rule remains intact: BIS has deferred the expanded controls, not withdrawn them.
The United States Capitol in Washington, D.C.
The midterm elections have set the stage for sustained congressional scrutiny of the Trump administration’s trade policies. Incoming Democratic chairs will gain the means to investigate tariff decisions, sanctions waivers, export licenses and sensitive investments, as well as companies’ dealings with the administration. But presidential veto power and bipartisan support for restrictions involving China will limit how far Congress can change the underlying policies.
IBM Q System One Quantum Computer.
New federal guidance makes post-quantum security a business planning issue today. NIST has outlined the transition from vulnerable cryptography, while CISA and its partners have published questions to help enterprises assess whether their technology suppliers can deliver the necessary changes.
ABB’s IRB 4600 industrial robot.

China’s Growing Influence over Third-Country Transactions

China’s reported move to block SoftBank’s acquisition of ABB’s robotics business underscores the growing importance of Chinese approval for transactions between non-Chinese companies.

U.S. Trade Deficit Holds Near $105 Billion as Computer Imports Surge

The U.S. trade deficit narrowed marginally in September as exports increased slightly faster than imports, but a continued surge in computer and capital-goods imports kept the monthly imbalance above …

TD Bank Executives Face Shareholder Lawsuit Over AML Failures

The lawsuit moves scrutiny of TD’s compliance failures beyond the branch employees prosecuted for facilitating money laundering to the disclosures and oversight responsibilities of senior management.

Technology Products Account for 61% of U.S. September Trade Deficit

“Only three years ago, the US was a net exporter of tech products!” wrote James Knightley, ING’s chief international economist for the United States.

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