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Reporting Requirements U.S. Commerce Department

Wilson Sonsini Goodrich & Rosati

Commerce Proposes New Reporting Requirement for Advanced AI Developers and Cloud Computing Providers

Last week, the U.S. Department of Commerce’s (Commerce) Bureau of Industry and Security (BIS) released a Notice of Proposed Rulemaking (NPRM) outlining a new mandatory reporting requirement for large-scale AI developers and...more

Fenwick & West LLP

Access Control and Emerging Tech Remain Top Priorities in BIS Regulatory Agenda

Fenwick & West LLP on

The Bureau of Industry and Security (BIS) has published its spring 2024 regulatory agenda along with the rest of the Commerce Department. Of note is the continued focus on access to emerging technology, particularly relating...more

Sheppard Mullin Richter & Hampton LLP

Commerce Updates Boycott Requester List

On June 27, 2024, the U.S. Department of Commerce, Bureau of Industry & Security (BIS) announced its first update to the boycott requester list. The list contains entities that have been reported by a U.S. person as having...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - June 2024

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On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Antiboycott Regulations

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During the mid-1970’s, the U.S. adopted two laws that seek to counteract the participation of U.S. citizens in other nations’ economic boycotts or embargoes. These antiboycott laws are the 1977 amendments to the Export...more

Ankura

U.S. Department of Commerce Issues Proposed Rule Impacting AI and U.S. IaaS Providers to Counter Foreign Malicious Actors

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On January 29, 2024, the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce issued a new proposed regulatory rule (the “Proposed Rule”), which will impose significant diligence, monitoring, and reporting...more

Davis Wright Tremaine LLP

Commerce Department Proposes Cybersecurity/AI Reporting and "KYC" Requirements for Certain Cloud Providers

The U.S. Department of Commerce's ("Commerce") Bureau of Industry and Security ("BIS") has issued a proposed rule (the "Proposed Rule") that would impose significant diligence, reporting, and recordkeeping requirements on...more

Skadden, Arps, Slate, Meagher & Flom LLP

Know Your Cloud Customer: Commerce Department Proposes To Regulate Foreign Access to US IaaS Products

On January 29, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) released a proposed rule (Proposed Rule) that would require U.S. cloud services providers (a.k.a. Infrastructure as a Service, or IaaS,...more

Kelley Drye & Warren LLP

Commerce Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

Blank Rome LLP

U.S. Department of Commerce Publishes Proposed Rule Imposing “Know Your Customer” and Reporting Requirements on U.S....

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The U.S. Department of Commerce (“Commerce”), Bureau of Industry and Security (“BIS”) recently issued a proposed rule aimed at preventing foreign actors from utilizing U.S. Infrastructure as a Service (“IaaS”) products (i.e.,...more

Akin Gump Strauss Hauer & Feld LLP

Akin Intelligence - November 2023

Welcome to the November edition of Akin Intelligence. Looking back, October 2023 may be remembered as the month when the U.S. government tried to assume the mantle of global leadership on responsible artificial intelligence...more

Holland & Knight LLP

What to Know About the New Artificial Intelligence Executive Order

Holland & Knight LLP on

President Joe Biden on Oct. 30, 2023, signed an expansive, 111-page Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (EO) in response to the administration's growing concerns...more

Perkins Coie

Mandatory BEA Foreign Investment-Related Surveys Filing Deadlines Fast Approach

Perkins Coie on

The Bureau of Economic Analysis (BEA) of the U.S. Department of Commerce is the government agency that compiles statistics about the U.S. economy, including the U.S. gross domestic product (GDP). BEA also compiles statistics...more

Partridge Snow & Hahn LLP

BE-12 Filing Deadline is Rapidly Approaching

The Department of Commerce’s Bureau of Economic Analysis (“BEA”) conducts a benchmark survey on foreign direct investment every 5 years. The BE-12 survey is the BEA’s most comprehensive survey and produces statistics on the...more

Davis Wright Tremaine LLP

Mandatory Survey of Foreign Direct Investment Due to BEA by May 31, 2023 - Commerce Department Uses Corporate Benchmark Surveys of...

The U.S. Department of Commerce's Bureau of Economic Analysis ("BEA") collects data regarding U.S. multinational enterprise investments and prepares official U.S. economic statistics through a series of quarterly, annual, and...more

Dorsey & Whitney LLP

Foreign-Owned U.S. Companies Must Soon Respond to Federal Survey

Dorsey & Whitney LLP on

The International Investment and Trade in Services Survey Act ("IITSSA"), 22 USC § 3101 requires the Bureau of Economic Analysis (“BEA”) within the U.S. Department of Commerce to conduct a national survey of foreign direct...more

Lowenstein Sandler LLP

Attention All U.S. Funds and Businesses With Foreign Investment: Required Department of Commerce Filings Due May 2023

Lowenstein Sandler LLP on

While many U.S. funds and businesses may not be aware of the Bureau of Economic Analysis (BEA) or its reporting requirements, they are still obligated to submit a filing to the BEA by May 2023. The BE-12 benchmark survey is...more

Hogan Lovells

U.S. Commerce, Treasury Departments issue reports on pending outbound investment screening regime

Hogan Lovells on

Congressionally-mandated reports recently issued by the U.S. Department of the Treasury and the U.S. Department of Commerce reinforce previously reported details of the outbound investment screening regime that the Biden...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2022 - Antiboycott Compliance for U.S. Companies

It’s 7:00pm on a Friday, and it’s also the last day of your company’s fiscal quarter. You’re the shipping department manager responsible for loading several crates of widgets onto a truck that will take them to JFK Int’l...more

BCLP

Antiboycott Updates and Compliance Recommendations

BCLP on

On June 7, 2021, US Department of Commerce, Bureau of Industry and Security (“BIS”) amended its Antiboycott provisions in Part 760 of the Export Administration Regulations (“EAR”) easing reporting requirements and business...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Removes UAE from List of Countries Requiring Cooperation with an International Boycott

Key Points - On April 8, the Treasury Department removed the UAE from its list of countries requiring cooperation with an international boycott, thereby removing the UAE from the scope of the Treasury Department’s...more

Lowenstein Sandler LLP

U.S. Companies Required To Report Foreign Investments: BEA’s Little-Known Reporting Requirements

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Many U.S. companies are unaware that a relatively unknown agency, the Bureau of Economic Analysis (BEA) at the Department of Commerce, administers mandatory reporting requirements that oblige ALL U.S. businesses to file...more

McCarter & English, LLP

Mandatory Deadline To File BE-10 Benchmark Survey Is May 29

The BE-10 Benchmark Survey of U.S. Direct Investment Abroad is a mandatory survey conducted once every five years by the Bureau of Economic Analysis (BEA) of the U.S. Department of Commerce to obtain current economic data on...more

Orrick, Herrington & Sutcliffe LLP

U.S. Companies Nearing Deadline to Report on Direct Investment Holdings Abroad

The U.S. Department of Commerce’s Bureau of Economic Analysis (“BEA”) collects statistics related to U.S. international investment and trade in services. This alert summarizes a current BEA reporting requirement related to...more

Dechert LLP

Department of Commerce Regulatory Changes: Eliminating Export Exemptions and Increasing Compliance Obligations to Gain Insight...

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On April 28, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) published two final rules and one proposed rule targeting national security controlled exports and reexports to China, Russia, and...more

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