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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

Limits of IEEPA’s Designation Authority

Over the first 100 days and beyond, the Trump Administration has deployed national security authorities in novel ways. Perhaps most notably, President Trump has asserted authority under the International Emergency Economic...more

Voluntary Disclosure of Export Control Violations is Critical for Settling Criminal Liability, DOJ Action Shows

The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more

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