The Bureau of Industry and Security (BIS) has issued new interpretive guidance and FAQs related to the new military end user rule. The guidance makes it very clear that BIS is implementing an extremely broad definition of the term military end user. Extreme due diligence will be required when exporting any product listed in Supplement 2 to Part 744 of the EAR when evaluating whether a license is required. For specific transaction evaluation please contact TSI Global Consulting at 210-757-0618.

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