August 27, 2026 through August 27, 2027. Covered sellers face a 100% monthly domestic sales requirement unless BIS grants an adjustment or exception.
Make buyer status a controlled field
Because the order requires covered monthly sales to U.S. persons, buyer status should not live only in an email or salesperson’s memory. Record the legal buyer, status conclusion, reviewer, date and evidence reference.
Keep the evidence behind the conclusion
The workbook should point to supporting corporate/customer records and any escalation used by the company’s compliance process. Syntera does not make the legal U.S.-person determination for the user.
Refresh when facts change
Buyer ownership, address, transaction structure or affiliate routing can change. Use review dates and exception flags to surface stale diligence.
Build the evidence while the transaction is current
The Syntera DPAS Covered-Material Sales Compliance & 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.