Category: Export Control Updates

Effective July 1, 2025 the U.S. Government ended comprehensive sanctions on Syria by lifting certain blocks and authorizing some previously prohibited transactions in support of the Syrian people and their new government as they rebuild their country.

If you are interested in pursuing activities with Syria, please contact our office at [email protected] so we can provide guidance regarding permissible activities.

While this change provides the potential for increased collaborations with Syria, there remain continued prohibitions in place targeting individuals and entities linked to the previous regime, terrorist organizations, and human rights abusers as well as a continuation of stringent controls on exports and reexports to Syria. Due to these factors transacting with Syria remains high-risk and certain activities continue to be impermissible.

Our office will continue to monitor the federal government’s response to transactions with Syria and can provide you with the most up-to-date guidance and support.

As of May 14, 2024, the U.S. Department of Commerce has added the University of Science and Technology of China (USTC) and the following institutes of the Chinese Academy of Sciences to the Entity List:

• Center for Excellence in Quantum Information and Quantum Physics
• Institute of Physics
• Key Laboratory for Quantum Information
• Shanghai Institute of Microsystem and Information Technology

Please note that the National Supercomputing Center Guangzhou (NSCC-GZ), which is associated with Sun Yat-sen University, is on the Entity List as well.

This means that the U.S. government has determined that these institutions engage in activities that are contrary to the national security or foreign policy interests of the United States.

As a result, an export license is required for all items subject to the Commerce Department’s export regulations, which includes all commercial and dual-use technology (even items that would not normally require a license to be exported to China) if the technology will be shared with these institutes at the Chinese Academy of Sciences, USTC, or NSCC-GZ. The license review policy is a presumption of denial.

Due to this policy, there is a significantly high risk that an inadvertent, unauthorized transfer of technology could occur, resulting in an export violation and associated reputational risk to faculty members and researchers.

If you are currently engaged with or considering any interactions with these institutions, contact [email protected] as soon as possible so that we can provide you with guidance regarding what activities are permissible.

If you need help screening potential collaborations, visitors, or other parties, please send us an email at [email protected].