Megan Mohler

Picture of Megan Mohler

Megan Mohler

Associate Attorney
Bust of a classical statue with a blindfold labeled BIS in front of a dark curtain.

Ignorance is Not Bliss: The BIS Affiliates Rule

October 2, 2026

By: Megan Mohler, Associate Attorney

The time has come. The U.S. Bureau of Industry and Security’s (“BIS”) Affiliates Rule that was postponed last year is slated to take effect November 10, 2026, barring another extension.
The Rule was initially set to start November 10, 2025 but was extended for a year, effectively giving exporters one-year notice to conduct due diligence within its customer base to ensure compliance with the Rule.

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Flags of the United States and Cuba with the word 'Sanctions' in the center.

“Juntos pero no Revueltos”: Recent Developments in U.S. Sanctions on Cuba and Venezuela

July 31, 2026

By: Megan Mohler, Associate Attorney and Eiyack Cacho Ayala, Associate Attorney at Braumiller Law Group
The U.S. sanctions landscape continues to evolve as the current Presidential Administration increasingly relies on sanctions and targeted licensing to advance its foreign policy objectives in Cuba and Venezuela. Although these policies pursue markedly different economic outcomes, both are implemented through the same sanctions framework.

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BIS

BIS “Affiliates Rule” Suspended One Year, But No Time to Rest

November 30, 2025

By: Megan Mohler, Associate Attorney

On November 10, 2025, the U.S. Bureau of Industry and Security (“BIS”) delayed the effective date of its new Affiliates Rule for a one-year period, until November 9, 2026, after U.S. and China trade talks. The Affiliates Rule, announced on September 29, 2025, expands export controls under the Export Administration Regulations (“EAR”) to extend to non-listed “affiliates” owned or controlled by listed entities (on the Entity List, the Military End User List “MEU”, or certain sanctioned parties) 50% or more in the aggregate.

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steel and aluminum

New Presidential Proclamations – Section 232 Duties on Certain Steel and Aluminum Products from Mexico

August 9, 2024

By Paul Fudacz, Partner, Braumiller Law Group and Senior Associate Attorney Megan Mohler

On July 10, 2024, the President issued two Presidential Proclamations related to the imposition of Section 232 duties on certain steel and aluminum products from Mexico. The first establishes a “melt and pour” requirement for imports of steel articles that are products of Mexico and will increase the section 232 duty rate for imports of steel articles and derivative steel articles that are products of Mexico that are melted and poured in a country other than Mexico, Canada, or the United States.

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BIS

Overview of BIS’s Interim Final Rules, Export Controls for Advanced Computing, Supercomputing, and Artificial Intelligence

November 8, 2023

By: Megan Mohler, Associate Attorney

On October 25, 2023, the Bureau of Industry and Security (“BIS”) published interim final rules amending the Export Administration Regulations (“EAR”) to add/clarify new controls on semiconductor manufacturing equipment (“SME”), advanced computing integrated circuits (“IC”), and computer commodities containing them.

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Russia remains one of the world’s top aluminum producers

Recent U.S. Actions Affecting Imports of Aluminum Products and More from Russia

April 5, 2023

By: Megan Mohler, Associate Attorney

With the signing of two recent Presidential Proclamations, the U.S. has chosen to take another hardline stance on Russia from an import perspective. Currently, Russia remains one of the world’s top aluminum producers, among other base metals and ore producers. This is troublesome for U.S. importers who still import base metals or derivative metal products from Russia, specifically aluminum.

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Prior disclosure

2022: Prior Disclosure Woes

February 6, 2022

By: Megan Mohler, Associate Attorney, Braumiller Law Group

The year is 2022, and companies are turning over a new leaf, making a concerted effort to become compliant with U.S. Customs laws and practices. Seemingly, there are no downsides to conducting a comprehensive Customs compliance review and submitting a Prior Disclosure under 19 U.S.C. § 1592(c)(4) and 19 C.F.R. § 162.74.

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icts Information and Communications Technology and Services

ICTS Transactions Rule Includes Imports and Uncertainty

February 1, 2021

By Attorneys, Megan Mohler and Vicky Wu, Braumiller Law Group

On January 19, 2021, the U.S. Department of Commerce published an interim final rule (interim rule) and proposed regulations (15 CFR Part 7) that could, effectively, mean a new licensing regime on imports related to Information and Communications Technology and Services (ICTS).

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