We assist clients to understand the Foreign Direct Product Rules (FDPRs). The U.S. enforces approximately 10 different FDPRs covering both jurisdictions and goods, including Russia, Belarus, Iran, national security, dual use goods, and advanced and super-computing.

Foreign-produced items located outside the United States are subject to the EAR when they are a “direct product” of specified “technology” or “software,” produced by a complete plant or ‘major component’ of a plant that itself is a “direct product” of specified “technology” or “software,” or, for specified foreign-produced items, contain an item produced by a complete plant or ‘major component’ of a plant that itself is a “direct product” of specified “technology” or “software.” If a foreign-produced item is subject to the EAR, then you should separately determine the license requirements that apply to that foreign-produced item (e.g., by assessing the item classification, destination, end-use, and end-user in the relevant transaction). Not all transactions involving foreign-produced items that are subject to the EAR require a license. Those transactions that do require a license may be eligible for a license exception.