Regulation

Managing Foreign Direct Product Rule compliance

STEPTOE: OUTSIDE COUNSEL
Ask any group of experienced export compliance managers what they view as the most complex sections of the EAR, and you’re sure to get several who point to BIS’s various Foreign-Direct Product Rules (“FDPRs”). While BIS has long controlled certain items that are made using US software, hardware, and technology, we have recently witnessed – through the proliferation of FDPRs – a dramatic expansion of US export controls jurisdiction over a wide array of non-US items. The c...

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Jonny Test