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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

BIS Implements New Controls on Additive Manufacturing, Quantum Computing, and Advanced Semiconductor Manufacturing

On September 6, 2024, the Bureau of Industry and Security (BIS) issued an interim final rule (the September 6 IFR) implementing new and revised export controls relating to emerging or critical technologies in the fields of...more

Biden Administration Further Expands Export Controls and Sanctions on Russia and Belarus

On June 12, 2024, ahead of the 2024 G7 Summit, the Biden administration introduced new export controls and sanctions on Russia and Belarus in an effort to limit Russia’s ability to continue its war efforts against Ukraine....more

BIS Expands Export Controls on Advanced Computing Integrated Circuits for Supercomputer and Semiconductor End Use, and on...

On October 17, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued new controls aimed at further slowing China’s development of advanced AI technologies. These new controls, published in two...more

Biden Administration Further Expands Export Controls and Sanctions on Russia and Belarus

On May 19, 2023, in conjunction with allies at the 2023 G7 Summit, the Biden administration announced several new actions to counter continued Russian aggression in Ukraine that, among other measures, include a significant...more

OFAC Penalizes Another Crypto Asset Company for Sanctions Violations

In keeping with its recent focus on the crypto asset industry, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced an agreement last week with crypto asset trading platform Poloniex, LLC...more

United States Imposes Export Restrictions on Beijing Genomics Institute (BGI) Group Subsidiaries over National Security Concerns

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule effective March 2, 2023, amending the Export Administration Regulations (EAR) by adding 37 entities to the Entity List, including...more

BIS Announces New End-Use Check Policy; Adds YMTC, 30 Additional Chinese Entities to Unverified List

On October 7, 2022, the Bureau of Industry and Security (BIS) announced a new policy that would continually escalate restrictions on entities that fail to comply with BIS’s end-use verification checks, regardless of whether...more

BIS Implements New Semiconductor- and Supercomputer-related Export Controls and End-Use Controls

On October 7, 2022, the Bureau of Industry and Security (BIS) issued a long-awaited interim final rule implementing new export controls on advanced computing chips, computers, and components including new Export Control...more

New Russia Sanctions Imposed as Ukraine War Continues: Expansion of Controls on EAR99 Items and Military End-Uses

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) announced an expansion of existing export controls and imposition of additional sanctions against the Russian Federation (Russia) and Belarus in response...more

Russia Sanctions Update: Intellectual Property General License and a Prohibition on the Provision of Some Services

New General License Permits Certain Russia-Related Intellectual Property Transactions - Last week, the Office of Foreign Assets Controls (OFAC) issued four new general licenses, most notably General License 31, which...more

New U.S. Sanctions on Russian Banks and Elites, Expanded Export Controls, and Other Updates

The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC or the Treasury) unveiled a new wave of sanctions targeted against Russia, Russian entities, and Russian individuals during the week of April 4, in...more

License Exception ENC Severely Limited for Exports to Russia and Belarus, Belarus Targeted by Biden’s Third Tranche of Controls,...

The Biden administration took further action this week to degrade the ability of Belarus and Russia to sustain a military campaign against Ukraine. The measures are the latest in a series of restrictions levied by the U.S. in...more

Biden Administration Implements Significant BIS Controls and Imposes Second Tranche of OFAC Sanctions in Russia-Ukraine Crisis

On February 24, 2022, the United States, in coordination with the European Union, the United Kingdom, Canada, Australia, Japan, and other allies, took further action against Russia and Belarus in response to Russia's invasion...more

Biden Administration Authorizes New Sanctions on Regions of Ukraine

New Sanctions Also Authorized on Russian Financial Institutions, Elites, and Sovereign Debt, with UK and EU Sanctions to Follow - The Biden administration announced measures this week in response to the Russian...more

U.S. State Department Proposes ITAR Revisions to Remove Prior Citizenship Status Considerations

The U.S. State Department has proposed revisions to multiple sections of the International Traffic in Arms Regulations (ITAR) to remove consideration of citizenships previously held by a foreign person. The State Department's...more

CJEU Publishes Judgment Interpreting the EU’s Blocking Regulation

In December 2021, the Court of Justice of the European Union (the CJEU) published a judgment interpreting the European Union's Blocking Regulation....more

2021 U.S. Sanctions Year in Review

In January 2021, President Biden was sworn into office and for the first time in a decade, Democrats assumed control of both chambers of Congress. Notwithstanding these changes, the U.S. government has continued to rely on...more

Intrusion Preclusion: BIS Issues Long-Awaited Controls on Cybersecurity Items, Creates New License Exception

On October 21, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (the rule) implementing expanded export controls on cybersecurity items based on the belief that these items...more

Electronics Testing Company Penalized $6.6 Million for Unauthorized Software Exports

The U.S. State Department's Directorate of Defense Trade Controls (DDTC) reached a $6.6 million settlement last week with California-based electronics testing company Keysight Technologies, Inc. for alleged illegal exports of...more

President Biden Issues Executive Order Amending Restrictions on Chinese Military and Surveillance Companies

On June 3, 2021, President Biden signed Executive Order 14032 (Addressing the Threat from Securities Investments That Finance Certain Companies of the People's Republic of China), modifying the prohibitions placed by the...more

U.S. Department of Commerce's Bureau of Industry and Security Relaxes Several Classification and Reporting Requirements for...

As of March 29, 2021, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) has implemented significant modifications to the Export Administration Regulations (EAR) that relax requirements on the...more

Take Two: Another Executive Order Addresses U.S. Personal Data Concerns by Prohibiting Business with Companies That Develop or...

On January 5, 2021, President Trump signed another executive order (EO) to address the threat to U.S. national security posed by access to personal data by the People's Republic of China and the Chinese Communist Party. This...more

U.S. Government Authorization Now Required for Certain Business with SMIC and Over 70 Additional Entities in China

As of December 18, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has added 77 new entities to the Entity List. Among the most notable additions are Semiconductor Manufacturing International...more

Export and CFIUS Implications: New Emerging Technologies Added to Export Control List

On October 5, 2020, the U.S. Commerce Department's Bureau of Industry and Security (BIS) released a final rule adding six recently developed or developing technologies to BIS's Export Administration Regulations' (EAR)...more

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