Export Administration Regulations compliance
Export Administration Regulations compliance in the Energy, Power & Commodities sector has grown materially more demanding since the Bureau of Industry and Security expanded its Entity List and tightened EAR99 classification reviews for dual-use energy technologies, including power grid components and LNG infrastructure equipment. The U.S. Department of Commerce's Bureau of Industry and Security and the Office of Foreign Assets Control are the primary federal authorities setting the tempo here, with the U.S. Department of Energy's Office of Electricity holding concurrent jurisdiction over certain cross-border electricity transfer authorizations. Compliance teams in this sector are currently stress-testing vendor and counterparty lists against updated country-group designations introduced under the Export Control Reform Act framework, with particular pressure on transactions touching Russia, China, and select Middle Eastern jurisdictions.
Watch
- BIS Entity List additions affecting power generation and grid equipment suppliers
- EAR99 reclassification risk for LNG heat exchanger and turbine components
- De minimis threshold rules applied to foreign-origin energy technology re-exports
- OFAC secondary sanctions exposure on commodity trading counterparties in restricted jurisdictions
Recent material activity in Energy, Power & Commodities
A selection of recent published briefs; this is not a complete archive.
DOE / EIA Energy Policy & Data release pending Cresthaven Analytics full analysis: Energy Department Announces Speed to Power Investments Across 26 States to Lower Electricity Costs and Improve Grid Reliability
DOE / EIA Energy Policy & Data published a regulatory release titled 'Energy Department Announces Speed to Power Investments Across 26 States to Lower Electricity Costs and Improve Grid Reliability'. Cresthaven Analytics…
Read a full sample brief →NRC proposes wholesale revision of reactor licensing, decommissioning, and operational oversight regulations under Executive Order 14300
On September 24, 2026, the NRC published a proposed rule to revise its reactor licensing, decommissioning, and operational oversight regulations. The proposal implements Section 5 of Executive Order 14300, which directs …
Read a full sample brief →EPA reopens public comment on 2024 Texas SIP disapproval covering emissions during power plant maintenance activities
The EPA granted reconsideration on May 11, 2026 of its December 20, 2024 disapproval of a Texas state implementation plan governing visible emissions and particulate matter during planned maintenance, startup, and shutdo…
Read a full sample brief →EPA proposes consent decree setting deadlines for overdue California and Colorado ozone SIP final actions
The EPA published notice on September 24, 2026 of a proposed consent decree in Center for Biological Diversity and Center for Environmental Health v. Lee Zeldin, No. 4:25-cv-10007-JST. The decree would resolve citizen-su…
Read a full sample brief →FERC opens intervention window on Transcontinental Gas Pipe Line Company natural gas pipeline application
FERC published a notice on September 24, 2026 opening the intervention deadline period for a Transcontinental Gas Pipe Line Company, LLC certificate or abandonment application. The notice establishes the procedural windo…
Read a full sample brief →FERC opens scoping period for LED Enterprises Yuma Pipeline Project environmental review
FERC issued a notice on September 24, 2026 opening a public scoping period for the proposed Yuma Pipeline Project by LED Enterprises, LLC. The notice solicits comments on environmental issues and announces a public scopi…
Read a full sample brief →FERC accepts GR Catalyst One LLC hydropower application and opens intervention and protest period
FERC accepted GR Catalyst One, LLC's application for filing on September 24, 2026, opening a formal proceeding for the project. This acceptance initiates the intervention and protest window, establishing the procedural r…
Read a full sample brief →AEMC releases draft rule enabling Commonwealth's $40 million EV charging infrastructure program across regional and urban sites
The AEMC released a draft rule on September 24, 2026 to support the Commonwealth Government's Accelerating EV Charging Program. The draft targets two specific gaps: regional charging blackspots and high-density kerbside …
Read a full sample brief →EPA proposes to approve North Carolina second 10-year ozone maintenance plan for Charlotte-Rock Hill area through 2035
EPA published a proposed rule on September 23, 2026 to approve North Carolina's second 10-year maintenance plan for the 2008 8-hour ozone standard covering the bi-state Charlotte-Rock Hill area. The proposal incorporates…
Read a full sample brief →FERC opens intervention deadline for High Island Offshore System pipeline application
The Federal Energy Regulatory Commission published a notice on September 23, 2026 establishing an intervention deadline for an application filed by High Island Offshore System, L.L.C. The notice opens the formal particip…
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