military, intelligence, and security end use and end user export controls; (2) impose corresponding controls on related U.S. person activities; (3) create export controls for certain facial recognition systems, software, and technology; and (4) impose changes related to defense services.On July 29, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) published complementary proposed rules to impose expanded controls related to military, intelligence, and security end uses and end users and related U.S. person activities, including defense services. BIS and DDTC are proposing these changes to advance U.S. national security and foreign policy interests. Companies have the opportunity to comment on the impact of these proposed rules, including any unintended consequences, by September 27, 2024.BIS published two proposed rules amending the Export Administration Regulations (“EAR”) (89 Fed. Reg. 60985 and 89 Fed. Reg. 60998), which would expand the current scope of the military and military-intelligence end use and end user controls in EAR Part 744. The expanded rules would capture almost all U.S. origin goods and technology involving certain end users and end uses, as well as add new controls on military support and foreign security end users. Significantly, the proposed rules also would impose controls on U.S. persons providing “support” to these types of end users and military production activities. In addition, BIS proposes adding new controls on certain facial recognitions systems and related software and technology that would control those items for export, reexport, or transfer to all countries other than close allies of the United States.DDTC concurrently published a proposed rule (89 Fed. Reg. 60980) revising the definition of defense services in the International Traffic in Arms Regulations (“ITAR”) to clarify the scope of the definition and enumerating certain controlled