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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On February 3, 2026, the Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) issued a <a href="https://www.federalregister.gov/public-inspection/2026-02262/export-administration-regulations-cambodia" target="_blank" rel="noreferrer noopener">final rule</a> removing Cambodia from the list of U.S. arms-embargoed countries&mdash;Country Group D:5&mdash;within the Export Administration Regulations (EAR).&nbsp;This actions follows the White House&rsquo;s <a href="https://www.whitehouse.gov/fact-sheets/2025/10/fact-sheet-president-donald-j-trump-secures-peace-and-prosperity-in-malaysia/" target="_blank" rel="noreferrer noopener">October 2025 decision</a> to lift the U.S. arms embargo on Cambodia, and aligns with the Department of State&rsquo;s Directorate of Defense Trade Controls <a href="https://www.federalregister.gov/documents/2025/11/07/2025-19822/international-traffic-in-arms-regulations-changes-to-section-1261" target="_blank" rel="noreferrer noopener">corresponding final rule</a> from November 2025 that amended the International Traffic in Arms Regulations (ITAR) by withdrawing Cambodia as a proscribed country (see <a href="https://www.thompsonhinesmartrade.com/2025/11/ddtc-amends-itar-to-remove-arms-embargo-on-cambodia/">Update of November 7, 2025</a>).
In the final rule, BIS explained the amendment related to Cambodia was necessary for two principal reasons.&nbsp;First, according to the final rule, the change reflects &ldquo;Cambodia&rsquo;s diligent pursuit of peace and security, including through renewed engagement with the United States on defense cooperation and combating transnational crime.&rdquo;&nbsp;Second, following the November 2025 ITAR amendment, Cambodia remained listed as an arms-embargoed destination under the EAR, even though the EAR provide that discrepancies between it and the ITAR are controlled by the ITAR, causing &ldquo;confusion on the part of exporters, reexporters, and transferors over differences between the list of countries subject to an arms embargo [when juxtaposing] both regulations.&rdquo;
The specific amendment related to Cambodia appears in Supplement No. 1 to Part 740 of the EAR, which lists the various country groups.&nbsp;Although Cambodia has now been removed from Country Group D:5, it remains in Country Group D, which applies heightened export controls to the jurisdictions is covers, and, more specifically, in Country Group D:1, which imposes controls based on national security concerns.&nbsp;Cambodia also remains subject to the military and military-intelligence end-use and end-user restrictions set forth in sections 744.21 and 744.22 of the EAR.

BIS Amends the EAR to Remove Arms Embargo Designation on Cambodia

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