August 27, 2026 through August 27, 2027. Covered sellers face a 100% monthly domestic sales requirement unless BIS grants an adjustment or exception.
Start with the four control questions
For every potentially covered transaction, document: whether the seller is a U.S. person; whether the material is covered; whether the buyer is a U.S. person; and whether the material remains physically in the United States. If an adjustment, exception or temporary license is involved, link the authorization to the transaction before relying on it.
Close the month, not just the transaction
The order is expressed as a 100% monthly domestic sales requirement. A month-end review should reconcile covered sales, buyers, quantities and values to source records and identify any transaction that lacks buyer-status or location evidence. For the month-end work, follow the DPAS monthly sales reconciliation guide to connect the sales population, supporting records and open issues.
Keep an evidence index
Invoices alone may not explain classification, buyer status, physical location or BIS authorization. Maintain a central index that points reviewers to diligence records, shipping/location evidence and correspondence.
Build the evidence while the transaction is current
The Syntera DPAS Covered-Material Sales, Authorization & Evidence System organizes material classification, buyer diligence, sales, physical-location evidence, BIS requests, supporting documents and month-end review in one Excel control system.
Official source
This guide is based on the BIS temporary final rule published August 6, 2026. Read 91 FR 50701–50706.
Educational information and operational control guidance only. Not legal advice or a determination that any particular material, buyer or transaction is covered.
After BIS approval, connect the written terms to every affected transaction. See the black-mass export license control workflow, including approved scope, dates, capacity and filing evidence.