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847 Awaiting Takeoff: DCSA Issues Guidance on Expanded Scope of FOCI Assessments

Section 847, which will expand foreign ownership, control or influence requirements to non-classified contracts, is on track for implementation in 2026. Section 847 of the National Defense Authorization Act for FY 2020...more

BIS Issues Interim Final Rule on Advanced Computing Integrated Circuits, Providing Long-Awaited Guidance on Due Diligence...

On January 15, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) updating export controls on advanced computing semiconductors. This IFR seeks to ensure that...more

The Treasury Department Finalizes U.S. Outbound Investment Rules

The Final Rule formalizes a new governmental system to monitor through a notification process and, when necessary, restrict investments in China that may be viewed as a national security risk. The regulations have broad...more

BIS Imposes New Export Controls on Quantum, Semiconductor and Additive Manufacturing Technologies

On September 5, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule imposing significant new export controls on quantum computing, cryocooling systems, semiconductor...more

U.S. Treasury Department Issues Proposed Rulemaking for Forthcoming Outbound Investment Program

The outbound investment program will affect U.S. persons considering certain investments or other transactions involving China and specific industry sectors (e.g., semiconductors, artificial intelligence and quantum...more

U.S. Increases Export Restrictions Against Nicaragua

The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the...more

Closing the Loopholes: Additional Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On November 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held a public briefing to address industry questions concerning the latest export controls on advanced computing and semiconductor...more

Long-Awaited Executive Order on Outbound Investment Issued: Regulatory Comment Process Commences in Advance of Implementation of...

On August 9, 2023, President Biden issued an Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. The new Executive Order (EO) is the...more

Commerce Department’s New ICTS Rule Raises Additional Considerations for Cross-Border Transactions

On January 19, 2021, the Commerce Department issued an interim final rule to implement the Executive Order on Securing the Information and Communications Technology and Services Supply Chain (E.O. 13873), which was issued on...more

U.S. Commerce Department Implements Multilateral Controls on Six Emerging Technologies

On October 5, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule that imposes new multilateral controls on six “emerging technologies,” agreed during the December 2019 plenary meeting...more

Supply Chain Threats and Cybersecurity Compliance Issues on the Horizon

New rules and developments continue to proliferate as the U.S. government seeks to minimize supply chain threats and cybersecurity risks. For contract awards issued after August 13, 2020, prime contractors must conduct a...more

Key Takeaways from CFIUS Final Rules Implementing FIRRMA

On January 13, 2020, the U.S. Department of the Treasury issued two final rules for the Committee on Foreign Investment in the United States (CFIUS) implementing the Foreign Investment Risk Review Modernization Act (FIRRMA),...more

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