[Revised] Effective July 10, 2026, and published in the July 14, 2026, Federal Register, the Bureau of Industry and Security has amended the EAR to provide enhanced favorable treatment to the United Arab Emirates. Specifically, BIS has moved the UAE into Country Group A:5 (see EAR Supplement 1 to Part 740), thus making the UAE eligible for License Exception STA (Strategic Trade Authorization) under EAR Part 740.20 for shipments to the UAE government including the Ministry of Defense and all branches of the Armed Forces. However, it is important to note that shipments to private sector contractors serving as Ultimate Consignee is limited to “approved commercial entities” which at this time ONLY includes a few select entities identified in a new Supplement 8 to Part 740. Companies may petition BIS to add private sector defense contractors in the UAE to the list of “approved commercial entities” for use of STA by making such requests via submission of an Advisory Opinion request. For our clients who export Series 600 military aircraft parts and components STA is still effectively not authorized unless BIS provides a case specific approval for the private sector integrators/ultimate consignee for the parts and components, but the good news is that the UAE Ministry of Defense and branches of the Armed Forces are eligible for use of STA for Direct shipments of most Series 600 aircraft parts and the use of license exception GOV in lieu of a license may, in some cases, be applicable as well (Note: The new regulation is not fully clear on eligibility of use of license exception GOV so we are looking into the matter and will update the blog with new details once confirmed) The UAE has been removed from Country Groups D:3 and D:4 which previously added restrictions on dual use items that had potential chemical and biological weapons use as well as missile technology design, development, production and use related applications. For further details on this new regulation and whether your transaction qualifies for a license exception to export to the UAE under the new enhanced treatment contact the office at 210-757-0618 or email jonathan.fink@tsiglobalconsulting.com
