Partner Melissa Mannino and Associate James Perry collaborated on a Dec. 30, 2025, article in Kharon’s The Brief titled “BIS Affiliates Rule and Brain Drain Will Continue to Impact U.S. Export Controls,” part of the publication’s wrap-up of 2025’s biggest storylines and predictions for 2026. In 2025, the Bureau of Industry and Security published their long-awaited Affiliates Rule on Sept. 29, only to suspend it for a year beginning Nov. 10, during U.S.-China trade negotiations. There was also the exit of a multitude of experienced personnel, many from the Export Administration unit – a loss that will have ramifications in 2026 and beyond.
Read the article. (subscription required)




