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US Export Controls on “AI Diffusion” Officially Paused, but New Guidance Elevates Risk for AI-Related Exports

On May 13, 2025, the Department of Commerce formally signaled its intention to rescind the Biden Administration’s Framework for Artificial Intelligence Diffusion (AI Diffusion Rule) two days before the January 2025 Interim...more

BIS Issues Long-Awaited Export Controls on AI

On January 13, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) released its export control titled “Framework for Artificial Intelligence Diffusion.” This new interim final rule creates a two-pronged...more

Hic Sunt Dracones: Biden’s BIS Issues Last Minute Export Controls, Most of Which Appear to Escape Trump’s Regulatory Freeze

In the last few days of the Biden Administration, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a flurry of new, noteworthy rules targeting national security risks in the science and...more

BIS Issues Export Control Compliance Requirements for Semiconductor Fabricators

On January 15, 2025, BIS issued an interim final rule controls targeting integrated circuits (“ICs”) fabricators. BIS is concerned that some IC designers have misrepresented the performance capabilities and intended end use...more

BIS Issues the Final Connected Vehicles Rule, But Trump’s Recent Presidential Action Throws Implementation into Question

On January 14, 2025, BIS released the final rule for Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles (Connected Vehicle Rule). The Connected Vehicle Rule prohibits imports...more

BIS Issues Sweeping Additional Restrictions on Semiconductors and Advanced Computing, Entity List Designations

On December 2, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released its third round of export controls primarily targeting China’s attempts to create an “independent and controllable”...more

BIS Sets Higher KYC Standards for Companies and Universities Over Russia Diversion Concerns

On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more

New Multi-Jurisdictional Sanctions Continue to Target Broad Scope of Activities With Russia

In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...more

BIS Adds New License Exception for Medical Devices to Russia, Belarus and Occupied Regions of Ukraine

Medical device companies have a new regulatory pathway for exporting certain U.S.-origin medical products to Russia, Belarus, Crimea and other regions of Ukraine (i.e., the so-called Donetsk People’s Republic and Luhansk...more

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

New Commerce Department FAQs Require Due Diligence by Exporters to Assess Chinese Military End Uses and Users

On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more

New Commerce Department Rules Restrict US Exports to China and Other Countries

Yesterday, the US Department of Commerce Bureau of Industry and Security (BIS) promulgated two new rules and issued a new proposed rule: ..A new final rule that will restrict previously permissible exports to China, Russia...more

The U.S. Administration Targets Huawei in Actions to Curtail its Involvement in U.S. Telecommunications Networks and Access to...

On May 15, 2019, President Trump issued an Executive Order (EO) declaring a national emergency and paving the way for a ban on the use of Huawei equipment and services in U.S. telecommunication networks. On the same day, the...more

The US Tightens Export Controls Targeting China

On August 1, 2018, the US Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register notice stating that the US government had identified 44 Chinese companies as acting contrary to US national...more

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