News & Analysis as of

Export Controls Bureau of Industry and Security (BIS)

Wilson Sonsini Goodrich & Rosati

From Embargo to Engagement: U.S. Reopens Doors to Syria

After the fall of the former regime of Bashar al-Assad in Syria, the Presidential Administration has taken steps to formally dismantle the U.S.’s two-decade-long comprehensive trade restrictions on Syria. These steps began...more

Troutman Pepper Locke

With Additional Syria Sanctions Relief, Risks Remain

Troutman Pepper Locke on

On June 30, 2025, President Trump issued an executive order (EO) that, effective July 1, revokes the U.S. sanctions program on Syria, and calls for the removal of the Syrian Sanctions Regulations from the Code of Federal...more

Kelley Drye & Warren LLP

White House Terminates Most Syria Sanctions

On June 30, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented the President’s Executive Order ​“Providing for the Revocation of Syria Sanctions,” (Syria EO) which removes U.S. sanctions on...more

A&O Shearman

DOJ Issues First-Ever Declination For Sanctions Violations Since Creation Of The M&A Safe Harbor Policy

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm...more

McDermott Will & Emery

From risk to relief: PE firm avoids prosecution with swift disclosure

In June 2025, the US Department of Justice (DOJ) announced that it declined to prosecute a private equity firm and its affiliates following the firm’s voluntary self-disclosure of criminal violations of US sanctions and...more

ArentFox Schiff

BIS Issues Two General Authorizations and More FAQs on the Connected Vehicles Rule

ArentFox Schiff on

On June 11, the US Department of Commerce, Bureau of Industry and Security (BIS) announced the release of two General Authorizations, accompanied by additional Frequently Asked Questions (FAQs) related to the January 16...more

Akin Gump Strauss Hauer & Feld LLP

Akin Intelligence - May 2025

On May 13, 2025, the Commerce Department’s Bureau of Industry and Security (BIS) announced that the Commerce Department initiated a rescission of the Biden Administration’s Framework for Artificial Intelligence Diffusion (“AI...more

Proskauer Rose LLP

DOJ Declination of Private Equity Firm Underscores Need for Robust M&A Due Diligence

Proskauer Rose LLP on

On June 16, 2025, the U.S. Department of Justice (“DOJ”), including its National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas, announced that they would not prosecute White Deer...more

The Volkov Law Group

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

The Volkov Law Group on

DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration.  DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

The Volkov Law Group on

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

Hinshaw & Culbertson LLP

[Event] U.S. Trade, Tariffs, and State of the Economy Forum - July 24th, Chicago, IL

Join us for U.S. Trade, Tariffs, and State of the Economy Forum, on July 24, 2025, at Hinshaw's Chicago office, an insightful discussion on U.S. trade, tariffs, and economic policies that brings together experts,...more

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

White & Case LLP on

In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

American Conference Institute (ACI)

[Virtual Conference] EAR Compliance & Licensing Masterclass - July 14th - August 7th, 12:00 pm - 3:00 pm EDT

The Trump Administration is aiming to eliminate loopholes in the U.S. export controls system, expand the scope of the EAR, and ramp up enforcement. Get the insights you and your team need to strengthen your compliance program...more

Morrison & Foerster LLP

AI Diffusion Rule Out but BIS Increases Compliance Obligations for Companies

On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a recission of the Biden administration’s January 15, 2025 Artificial Intelligence Diffusion Interim Final Rule (“AI Diffusion...more

Vinson & Elkins LLP

Commercial Considerations Related to the Shift in Syrian Sanctions Policy

Vinson & Elkins LLP on

On May 23, 2025, General License 25 (“GL 25” or the “General License”) was issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), suspending a wide array of sanctions against Syria....more

Morrison & Foerster LLP

Trump Administration Issues Broad Sanctions Relief for Syria, Effectively Lifting 14 Years of Comprehensive Economic Sanctions –...

On May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more

Womble Bond Dickinson

FCC Proposes to Add Certain Connected Vehicle Technologies to the Covered List

Womble Bond Dickinson on

The Federal Communications Commission’s (FCC or Commission) Public Safety and Homeland Security Bureau (Bureau) and Office of Engineering and Technology (OET) have published a Public Notice seeking input on adding certain...more

Hogan Lovells

OFAC lifts certain sanctions on Syria, broad export controls remain in place

Hogan Lovells on

General License (GL) 25 authorizes transactions previously prohibited by various regulations. Specifically, Section (a) broadly authorizes activities previously prohibited under the Office of Foreign Asset Control (OFAC)’s...more

Pillsbury - Global Trade & Sanctions Law

Trump Administration Rescinds Biden’s AI Diffusion Rule

Two days before its scheduled effective date, the Department of Commerce’s Bureau of Industry and Security (BIS) announced the rescission of the Biden administration’s Artificial Intelligence (AI) Diffusion Rule on May 13....more

WilmerHale

The United States and European Union Offer Sanctions Relief to Post-Assad Syria

WilmerHale on

Following the fall of Syria’s Assad regime, the United States and key allies have recently announced sanctions relief with the stated goal of stabilizing Syria under its newly installed leaders. ...more

A&O Shearman

AI diffusion rule rescinded; policy guidance for advanced integrated circuits and commodities issued

A&O Shearman on

The U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced on May 13, 2025, its plans to rescind the Artificial Intelligence Diffusion Framework (the Rule), the Biden-era regulation that imposed a...more

Benesch

Syria Sanctions - New General License Issued by OFAC Following Trump Announcement

Benesch on

President Trump announced plans to relax sanctions against Syria during his recent trip to the Middle East, where he visited with the country’s President, Ahmed al-Sharaa. ...more

Hogan Lovells

BIS announces rescission of Biden-Era AI Diffusion Rule and issues new AI policy and guidance

Hogan Lovells on

At the same time that it potentially reduced licensing requirements on advanced computing items to a smaller group of countries by notifying industry that it started the process to rescind the AI Diffusion Rule, the U.S....more

Husch Blackwell LLP

BIS Announces Proposed Additions to Section 232 Steel and Aluminum Tariffs, Opens Public Comment Period

Husch Blackwell LLP on

On May 22, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) released a diverse list of 58 requests for new products to be added to the list of derivatives subject to the Section 232 tariffs on steel...more

Wiley Rein LLP

BIS Rescinds AI Diffusion Rule and Issues Guidance on Advanced Computing Integrated Circuits

Wiley Rein LLP on

On May 12, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced the rescission of the previously issued Framework for Artificial Intelligence (AI) Diffusion Rule. The following day, May 13,...more

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