On Friday, October 7, 2022, the Bureau of Industry and Security (BIS) released an interim final rule containing an enormous set of export controls that will likely damage the Chinese semiconductor, advanced computing, and...more
10/11/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Federal Register ,
Interim Final Rules (IFR) ,
License Applications ,
Manufacturers ,
Military End Use ,
MOFCOM ,
Popular ,
Rulemaking Process ,
SDN List ,
Semiconductors ,
Software ,
Technology
The subpoena issuance suggests that the Biden Administration will continue the US Government’s assertive approach to China.
The US Department of Commerce, on March 17, 2021, issued subpoenas on multiple Chinese companies...more
3/19/2021
/ Biden Administration ,
China ,
Executive Orders ,
Foreign Adversaries ,
Foreign Policy ,
Information and Communication Technology (ICT) ,
Interim Final Rules (IFR) ,
National Security ,
Supply Chain ,
Trump Administration ,
U.S. Commerce Department
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule.
In an interim rule published on, January 15, 2020, the Department of...more
3/17/2021
/ Biological-Weapons ,
Bureau of Industry and Security (BIS) ,
Chemical Weapons ,
China ,
Cuba ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Interim Final Rules (IFR) ,
Iran ,
North Korea ,
Nuclear Weapons ,
Russia ,
Syria ,
Trump Administration ,
U.S. Commerce Department ,
Venezuela
The Information and Communications Technology and Services (ICTS) Rule, if implemented by the Biden Administration, would significantly impact companies that have an international nexus in a number of different sectors,...more
2/2/2021
/ Biden Administration ,
China ,
Cuba ,
Department of Homeland Security (DHS) ,
Digital Service Providers ,
Executive Orders ,
FCC ,
Foreign Adversaries ,
Information and Communication Technology (ICT) ,
Interim Final Rules (IFR) ,
Iran ,
National Intelligence Agencies ,
North Korea ,
Popular ,
Russia ,
Sensitive Personal Information ,
Software ,
Supply Chain ,
Telecommunications ,
Venezuela
BIS will be looking at items that are controlled only for anti-terrorism, crime control, short supply, United Nations embargoes, or designated as EAR99 in establishing new Foundational Technologies Controls.
Two years...more
8/28/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Embargo ,
Export Control Reform Act (ECRA) ,
Exports ,
FIRRMA ,
Interim Final Rules (IFR) ,
Military End Use ,
National Security ,
Rulemaking Process ,
United Nations
On August 17, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule (the Final Rule) (1) adding additional Huawei non-US affiliates to the Entity List, (2) confirming the expiration of...more
The good news is that, for the most part, State resisted the temptation to do something just a little different in the ITAR regulation, so the joint Commerce-State solution works. The chart below provides a quick side-by-side...more
1/3/2020
/ Cloud Computing ,
Comment Period ,
Encryption ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exporters ,
Interim Final Rules (IFR) ,
ITAR ,
Technology ,
U.S. Commerce Department ,
US Department of State