The UAE Joins United States’ Closest Export Control Partners: Key Takeaways from the BIS Final Rule

Effective immediately, the United Arab Emirates has been removed from Country Groups D:3 and D:4 and added to Country Group A:5. This new country group designation allows exports of items controlled for chemical, biological or missile technology reasons to qualify for license exceptions that were previously unavailable to the UAE under its former Country Group classification. In addition, the end-use restrictions in EAR 744.3—including restrictions applicable when an exporter knows an item will be used in the design, development, production, operation, installation (including on-site installation), maintenance, repair, overhaul, or refurbishing of rocket systems (including ballistic missiles, space launch vehicles and sounding rockets) or unmanned aerial vehicles capable of traveling at least 300 kilometers—no longer apply to exports to the UAE.

As a result, exporters may now export items for use in such UAVs without obtaining an export license under 744.3, provided the item is not otherwise subject to a license requirement under the EAR (e.g., based on its ECCN or another applicable end-use or end-user control).

Another significant development is the UAE’s new eligibility for License Exception Strategic Trade Authorization (STA), subject to the limitations set forth in 15 C.F.R. 740.20(c)(2). Under STA, certain eligible items may now be exported, reexported, or transferred (in-country) to or within the UAE, provided that the ultimate consignee and all end users—as defined in 15 C.F.R. 748.5(e) and (f)—are approved entities listed in Supplement No. 8 to Part 740. Accordingly, the UAE Government and approved commercial entities in the UAE are now eligible, as specified in Supplement No. 8, to receive exports, reexports and transfers (in-country) of items controlled for National Security (NS), Chemical & Biological Weapons (CB), Nuclear Nonproliferation (NP), Regional Stability (RS), Crime Control (CC), and Significant Items (SI) reasons—including deemed exports and deemed reexports to UAE nationals. Other non-U.S. commercial entities in the UAE may apply to become approved entities by submitting an advisory opinion request consistent with 15 C.F.R. 748.3(c).

License Exception STA
Exporters may use License Exception STA if all parties to the transaction, including the ultimate consignee, are either an approved commercial entity or the UAE Government. For these purposes, the “UAE Government” includes the Ministry of Defense and Armed Forces, but does not extend to state-owned corporations or to contractors or grantees of UAE government agencies. The approved UAE commercial entities currently eligible for STA are identified in Supplement No. 8 to Part 740, which presently includes Group 42 Holding Ltd (a/k/a G42) and Core42 Technology Projects LLC (d/b/a Core42). Please note that the STA eligibility for these two UAE commercial entities is time-limited: it will expire 270 days from July 10, 2026, unless these companies become U.S. companies. Otherwise, they will need to apply for continued STA eligibility by submitting an advisory opinion request pursuant to 15 C.F.R. 748.3(c).

Advanced Computing Items (e.g., ECCNs 3A090.a/.b, 4A090.a/.b)
In addition to the STA provisions, the Final Rule includes a new license exception for Advanced Computing Items, which authorizes exports of advanced semiconductor chips to the UAE—but only to the approved parties listed in Supplement No. 8 to Part 740, similar to the STA framework described above. This means the same Supplement No. 8 governs eligibility for both STA-eligible items and advanced AI-related items. Notably, BIS will continue to enforce license requirements for advanced chips exported to parties in the UAE that are not listed in Supplement No. 8. Therefore, the Advanced Computing Items license exception applies only to certain approved entities. Similar to the STA eligibility process, commercial entities in the UAE—including U.S.-headquartered AI companies—may submit an advisory opinion request under 15 C.F.R. 748.3(c) for review. BIS is evaluating applications for approved-entity status under Supplement No. 8 on a case-by-case basis. The Final Rule reminds industry that license exception eligibility does not preclude compliance with end-use and end-user restrictions set forth in 15 C.F.R. Part 744.

Of particular interest, BIS states in the Final Rule that license applications from UAE-headquartered company MGX for the export of semiconductors and servers to the UAE will receive favorable review.

Certain U.S.-Headquartered AI Companies
Supplement No. 8 to Part 740 also includes a Paragraph (c) listing certain predetermined trusted end users that are the subsidiaries of certain U.S.-headquartered AI companies. These entities are eligible to receive Advanced Computing Items without a license, and other items eligible for License Exception STA may also be exported to them.

This Final Rule is effective as of July 10, 2026.