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BIS Affiliates Rule Suspended for One Year

The White House has announced a one-year suspension of the Commerce Department Bureau of Industry and Security’s (BIS) new Affiliates Rule, but its scope remains unclear. As of November 3, 2025, BIS has not issued a rule or guidance formalizing the suspension. Exporters should continue preparing for compliance while monitoring forthcoming BIS action expected by November 10, 2025.

Weaponized Law as a Trade Tool

The ZTE case illuminates a potentially transformative shift in how the United States deploys its legal and regulatory authority in the international economic arena—a development with profound implications for global commerce, compliance practices, and the rule of law.

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