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BIS announces rescission of Biden-Era AI Diffusion Rule and issues new AI policy and guidance

At the same time that it potentially reduced licensing requirements on advanced computing items to a smaller group of countries by notifying industry that it started the process to rescind the AI Diffusion Rule, the U.S....more

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

U.S. Department of Commerce expands controls on advanced semiconductors and establishes new controls on closed AI model weights

The new interim final rule imposes new global licensing requirements for ECCNs 3A090.a, 4A090.a, and corresponding .z items; controls for closed AI model weights; updated data center validated end-user authorizations;...more

New DOJ rule limits cross-border data transfers to protect national security

The Department of Justice (DOJ) has issued a final rule limiting data transfers to China, Russia, and other designated “countries of concern.” The rule establishes a new national security program that bans specific types of...more

Final rule expands CFIUS’s reach over real estate transactions

On November 1, 2024, the U.S. Department of the Treasury (“Treasury”), in its role as chair of the Committee on Foreign Investment in the United States (“CFIUS”), issued a final rule (the “Final Rule”) amending CFIUS’s...more

DOJ proposes regulations limiting certain data transfers to protect national security

The U.S. remains on course to restrict a broad range of cross border data transfers to China, Russia, and other designated countries. On October 21, 2024, the Department of Justice (DOJ) issued a Notice of Proposed Rulemaking...more

U.S. eases Venezuela sanctions following electoral roadmap agreement

In recognition of political progress between the Government of Venezuela and opposition parties—notably, the signing of an electoral roadmap agreement between the Unitary Platform and representatives of Nicolas Maduro--the...more

US intensifies export control restrictions on semiconductor and supercomputing activities

The Department of Commerce’s Bureau of Industry and Security issued two interim final rules to expand on the 7 October 2022 restrictions aimed at denying access to certain advanced semiconductors, semiconductor manufacturing...more

U.S. agencies signal reinforced export enforcement collaboration and partnership

The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more

Legislation to grant U.S. government sweeping authority over ICT-related national security threats

On 7 March 2023, U.S. Senators Mark Warner and John Thune introduced the Restricting the Emergence of Security Threats that Risk Information and Communications Technology (RESTRICT) Act, sweeping legislation aimed at...more

Significant new U.S., UK and EU measures mark anniversary of Russia’s invasion of Ukraine

On 24 February 2023, the U.S. intensified its sanctions on Russia and released new trade control measures targeting key sectors, evasion efforts, and military supplies. Taken together, the additional sanctions, export...more

Aerospace & Defense Insights | DDTC outlines expectations for global compliance

Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more

U.S. implements new export controls on toxins, plant pathogens and biological equipment

The United States Department of Commerce’s Bureau of Industry and Security has issued regulations to amend the Export Administration Regulations to implement changes to controls of certain viruses, marine toxins, plant...more

BIS imposes significant new export controls on China regarding semiconductors and supercomputers

The Department of Commerce’s Bureau of Industry and Security has issued an interim final rule to deny China’s access to certain semiconductor and advanced computing technology and to inhibit China’s ability to manufacture...more

OFAC issues guidance on implementation of G7 price cap on Russian crude oil and petroleum products

On 9 September 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published “Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne...more

U.S. prohibits imports of Russian gold and imposes new sanctions in latest measures against Russia

The U.S. Government has imposed additional punitive measures against Russia in response to Russia’s actions in Ukraine.  The new measures include a prohibition on imports of Russian gold into the United States, new SDN and...more

BIS continues to expand export controls on Russia and Belarus and adds 71 entities to the Entity List

On 2 June 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) issued two final rules, effective on the same day, that revised the Export Administration Regulations (“EAR”) pertaining to the U.S.’s...more

OFAC Authorizes Transactions in Listed Sectors in Connection with Non-Regime Held Areas of Syria

The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more

Summary of February 24 U.S. sanctions and export controls on Russia

On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more

Ransomware sanctions and the U.S. Government's latest strategy to address cyber threats

The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more

Doing business in the United States

The U.S. is one of the easiest jurisdictions in the world in which to do business1 . 1 Regulatory barriers are generally low, establishing a branch or business entity is quick and easy, labor and employment laws are much...more

Cuban Assets Control Regulations amendments further restrict travel and trade

The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more

President issues executive order eliminating Hong Kong's preferential treatment

On 14 July, the same day the president signed into law the Hong Kong Autonomy Act (the act), President Trump issued the Executive Order on Hong Kong Normalization (the EO) directing federal agencies to impose a range of trade...more

BIS issues frequently asked questions to clarify the military end use/user rule

On 29 June 2020, the final rule expanding the military end user/user controls (MEU) issued by the Bureau of Industry and Security (BIS) went into effect. On 26 June 2020, BIS issued an FAQs guidance document that provides...more

China Entity List designations

On Friday, May 22, 2020, the US Department of Commerce, Bureau of Industry and Security (BIS) announced in two separate press releases that it would be adding a number of companies and governmental entities to the Entity...more

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