International Legal Perspective. U.S. Export Controls Upgrade: BIS Revises Iran's FDP Rules.


Published:

2024-07-31

On July 23, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) amended the Iran Foreign Direct Product Rules (Foreign Direct FDP Rules), which became effective on that date. BIS revised the Iranian FDP rules to further restrict Iran's ability to acquire key technologies and components by expanding the scope of export controls to Iran, thereby weakening its military strength and international influence.

On July 23, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) amended the Iran Foreign Direct Product Rules (Foreign Direct FDP Rules), which became effective on that date. BIS revised the Iranian FDP rules to further restrict Iran's ability to acquire key technologies and components by expanding the scope of export controls to Iran, thereby weakening its military strength and international influence.

 

1. Iran FDP rules specific amendments

 

By expanding the scope of the Iranian FDP rules, the BIS seeks to restrict Iran's indirect access to U.S. technology or technology products subject to U.S. export controls. The specific amendments are as follows:

 

 

Impact of 2. BIS Revising New Iranian FDP Regulations

 

The above amendments significantly expand the scope of application of the Iranian FDP rules and increase the complexity and rigour of export controls to Iran. For foreign-produced items involving U.S. technology or software, exporters need to assess compliance more carefully and trade within the strict scope of Iran's FDP rules to avoid the risk of non-compliance. For products or technologies that meet the requirements of the Iranian FDP rules, exporters need to apply for licenses in a timely manner to ensure compliance with the transaction.

 

3. Compliance Advice to Exporters

 

 

Summary

 

The Iranian FDP rules are an important part of the U.S. export control policy toward Iran. In the future, the United States may continue to strengthen export controls to cover more areas and products to safeguard its national security and economic interests. Enterprises should strengthen compliance management, adjust export strategies, strengthen international cooperation, and maintain a high degree of vigilance and flexible response capabilities to ensure the steady development of business.

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