On 3 February, the US Department of Commerce (“Commerce”) published changes to the US Export Administration Regulation’s (“EAR’s”) Foreign Direct Product Rule (“FDPR”) in the Federal Register. The changes were effective upon publication. (See 87 Fed. Reg. 6022, 3 February 2022). The new version of the FDPR is better organized and consolidated, making it easier to apply. However, the 3 February modifications also included one correction that expands the applicability of the rule in some cas...
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