Export controls from the Bureau of Industry and Security (BIS): Entity List additions and removals, license requirements, and Export Administration Regulations (EAR) rules.
Exporters cannot treat the sanctions as a blanket ban or assume prior Sudan licensing policy still applies. The controlling question is whether the item is on the Commerce Control List and whether the transaction fits an expressly preserved exception or licensing category.
US -> SudanState DepartmentBISCommerce Control List items+2
Reclassify open Sudan orders as CCL or non-CCL, check the end user and end use, document any reliance on CCD, GOV, ENC, BAG, TMP, RPL, TSU, or ACE, and obtain BIS or trade-counsel guidance before shipping a CCL item outside the notice's narrow licensing paths.
Exporters and temporary travelers must distinguish the rules already effective from the later jurisdiction transfer. The revised TMP exception can cover limited company-owned firearms and related items used temporarily abroad, while the November change moves only specified suppressors to EAR licensing and license-exception rules.
Specified suppressors transfer from the USML to the EAR
US -> GlobalBISState DepartmentCBP+4
Classify suppressors by the firearms they are designed for, separate fully automatic-firearm items, review existing State and Commerce authorizations, update temporary-export and CBP declaration procedures for the July 23 TMP changes, and prepare licensing and screening controls for the November 20 EAR transfer.
U.S. exporters and reexporters shipping EAR items to the UAE may gain access to broader License Exception treatment, including STA eligibility tied to Country Group A:5. For advanced-computing and AI infrastructure supply chains, the new Supplement No. 8 framework creates a preapproved path for listed U.S. companies shipping to approved UAE end users, while other UAE entities may seek case-specific advisory opinions.
United Arab EmiratesCommerceBISEAR license exceptions+5
Review UAE export workflows against the new Country Group A:5 status, confirm whether any planned shipments rely on License Exception STA or other A:5 treatment, and check whether advanced-computing transactions involve a Supplement No. 8 approved U.S. company or UAE end user. If your UAE counterparty is not listed, assess whether to request a BIS advisory opinion within the rule's 30-day window.