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
5/16/2025
/ Artificial Intelligence ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Export Controls ,
Exports ,
Interim Final Rules (IFR) ,
National Security ,
New Guidance ,
Popular ,
Semiconductors ,
Trump Administration ,
U.S. Commerce Department
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
5/6/2025
/ Business Entities ,
Compliance ,
Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
National Security ,
Non-Prosecution Agreements ,
Sanction Violations ,
Self-Reporting ,
Voluntary Disclosure
Recent actions by the Singapore and US governments following DeepSeek’s alleged use of restricted artificial intelligence (AI) chips signal more robust enforcement of export controls. Not only is Singapore stepping up its...more
4/29/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Enforcement Priorities ,
Export Controls ,
National Security ,
Risk Mitigation ,
Semiconductors ,
Singapore ,
Technology Sector ,
U.S. Commerce Department
On February 1, 2025, the Trump Administration announced that it would impose tariffs on imports of certain goods from Canada, Mexico and China, to be effective February 4, 2025. Although the Trump Administration reached...more
2/10/2025
/ Antitrust Investigations ,
China ,
Export Controls ,
Imports ,
International Trade ,
National Security ,
Tariffs ,
Trade Relations ,
Trade Retaliation ,
Trade Wars ,
Trump Administration ,
Unfair Competition ,
US Trade Policies
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
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
2/6/2025
/ Artificial Intelligence ,
Biden Administration ,
Biotechnology ,
Bureau of Industry and Security (BIS) ,
Connected Cars ,
ECCNs ,
Export Controls ,
Final Rules ,
National Security ,
Regulatory Freeze ,
Semiconductors
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
2/6/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Due Diligence ,
Entity List ,
Export Controls ,
Final Rules ,
Interim Final Rules (IFR) ,
National Security ,
Semiconductors ,
Supply Chain ,
Technology Sector
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
2/6/2025
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Connected Cars ,
Export Controls ,
Final Rules ,
National Security ,
Russia ,
Supply Chain ,
Trump Administration ,
U.S. Commerce Department
On January 15, 2025, BIS issued an Interim Final Rule that amends the Export Administration Regulation (EAR) to address dual use export control concerns about biotechnology. ...more
2/6/2025
/ Artificial Intelligence ,
Biotechnology ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Food and Drug Administration (FDA) ,
Interim Final Rules (IFR) ,
International Trade ,
Life Sciences ,
National Security ,
Regulatory Requirements ,
Technology Sector
China this past fall imposed an additional series of trade and other measures to counter actual and prospective trade measures by the United States with particular impact on semiconductors and raw materials, challenging the...more
President-elect Trump’s election victory has renewed the focus on international trade as a top-line concern for corporate executives. During the campaign, the president-elect expressed support for tariffs and other trade...more
12/16/2024
/ Canada ,
China ,
Economic Sanctions ,
Export Controls ,
Exports ,
Federal Procurement Systems ,
International Trade ,
Mexico ,
Outbound Transactions ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA)
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
12/9/2024
/ Bureau of Industry and Security (BIS) ,
China ,
ECCNs ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Inspections ,
Military End Use ,
Semiconductors ,
Software ,
Software Developers ,
Technology Sector ,
U.S. Commerce Department
As governments globally resort to more muscular uses of economic tools, such as sanctions and export controls for national security and foreign policy purposes, international trade has become increasingly complex. In this...more
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
7/29/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Colleges ,
Compliance ,
Due Diligence ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Federal Contractors ,
National Security ,
Popular ,
Russia ,
Ukraine ,
Universities
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
7/1/2024
/ Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Trade Regulations ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Technology ,
UK ,
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
5/6/2024
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Crimea ,
Entity List ,
Exceptions ,
Export Controls ,
General Licenses ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Requirements ,
Russia ,
TSRA ,
Ukraine
On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more
4/30/2024
/ Appropriations Bill ,
Biden Administration ,
China ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Federal Budget ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Israel ,
Russia ,
TikTok ,
UK ,
Ukraine
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