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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

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

DOJ Issues Guidance for New Data Security Program

On April 8, the Department of Justice’s (“DOJ’s”) final rule on Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (the “Rule”) formally took effect. ...more

New Executive Order Seeks to Bolster DOGE Role in Federal Grants and Contracts

On February 26, 2025, President Trump issued an executive order titled “Implementing the President’s ‘Department of Government Efficiency’ Cost Efficiency Initiative” (“EO”). The EO contemplates significant changes to federal...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

8 Questions To Ask Before Final CISA Breach Reporting Rule

On April 4, the Cybersecurity and Infrastructure Security Agency published a notice of proposed rulemaking setting out mandatory reporting requirements for covered entities that experience cybersecurity incidents or make...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

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