On January 15, 2021, the Bureau of Industry and Security (BIS) published an Interim Final Rule to implement new end-user and end use controls mandated by the Export Control Reform Act of 2018 (ECRA).
The rule adds in particular a new control that will require U.S. persons to obtain a license before “supporting” certain “military-intelligence” end uses and end users in China, Russia, Venezuela, and Country Group E:1 and E:2 destinations. The rule will also prohibit any person from exporting, reexporting, or transferring any item subject to the EAR to military-intelligence end uses and end users in those countries.
US Legislation will make a differentiation between "military end users" and "military-intelligence end users", the latter being intelligence and reconnaissance organization of the armed services (army, navy, marine, air force, coast guard) or national guard. The new rules are taking effect on 16 March 2021.