BIS: Trade and Sanctions Operations Face Uneven Impact Under Potential Government Shutdown

BIS: Trade and Sanctions Operations Face Uneven Impact Under Potential Government Shutdown

If a partial government shutdown begins January 31, the Bureau of Industry and Security (BIS) is expected to continue normal operations because funding for the Department of Commerce has already been approved by Congress. In contrast, agencies within the Department of the Treasury, including the Office of Foreign Assets Control (OFAC), would be impacted, as Treasury funding remains unresolved. The State Department would also be affected, including its Office of Economic Sanctions Policy and Implementation, which plays a key role in sanctions designations.

Several partner government agencies involved in import regulation—such as the Environmental Protection Agency (EPA), U.S. Fish and Wildlife Service, and the U.S. Department of Agriculture (USDA)—have already secured funding and should continue operations. However, the Food and Drug Administration (FDA) would be subject to shutdown impacts if all remaining funding packages fail to pass the Senate. Based on prior shutdowns, U.S. Customs and Border Protection (CBP) is expected to continue processing imports and issuing rulings. This analysis focuses solely on the operational and compliance implications for the trade community, without addressing the broader political context.

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