News & Analysis as of

Export Controls Bureau of Industry and Security (BIS)

Wiley Rein LLP

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

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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

Akin Gump Strauss Hauer & Feld LLP

BIS Rescinds Its AI Diffusion Rule and Issues Compliance Guidance Regarding Advanced Computing Items

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a series of significant updates affecting export controls on advanced computing integrated circuits (ICs), artificial intelligence (AI)...more

Jenner & Block

Client Alert: What’s Next for the AI Diffusion Rule

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The Trump administration recently announced its intent to scrap the so-called AI diffusion rule, a complex regulation the Biden administration published in January to govern the global export of AI technology and maintain US...more

Husch Blackwell LLP

Week Seventeen in Trade

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CBP Issues Facility Requirements for Bonded Warehouses In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do...more

Sheppard Mullin Richter & Hampton LLP

Throwing Away the Toaster: Where AI Controls Are Now and May be Heading

Anyhow, on a possibly related note, on May 14, 2025, BIS announced that it will rescind the AI Diffusion Rule and that, until the time of the official recission, would not enforce the Biden-era regulation. Stop-Gap Stopped -...more

WilmerHale

US Export Controls on “AI Diffusion” Officially Paused, but New Guidance Elevates Risk for AI-Related Exports

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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

Alston & Bird

Commerce Rescinds AI Diffusion Rule, Releases Other Guidance Involving Overseas AI Chips

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On May 13, 2025, the Department of Commerce, Bureau of Industry and Security (BIS) officially rescinded the Framework for Artificial Intelligence Diffusion (“AI Diffusion Rule”), that was published during the last week of...more

ArentFox Schiff

BIS Issues Long-Awaited FAQs on the Connected Vehicles Rule — But Questions About the Scope of the Rule Still Remain

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On April 28, the US Department of Commerce, Bureau of Industry and Security (BIS) published the long anticipated Frequently Asked Questions (FAQs) regarding the January 16 Information and Communication Technology and Services...more

The Volkov Law Group

Voluntary Self-Disclosure Shields Universities Space Research Association from Prosecution by DOJ

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On April 30, 2025, the U.S. Department of Justice’s National Security Division (“NSD”) issued a formal declination of prosecution to the Universities Space Research Association (“USRA”) following the organization’s timely and...more

Guidepost Solutions LLC

Unlocking Opportunity: Navigating the New Data Center Validated End User Program

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a significant interim final rule (IFR) that has created both challenges and exciting opportunities for these operators. This IFR...more

Husch Blackwell LLP

BIS Publishes Process for Requesting Inclusion of Section 232 Derivatives

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The Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule effective April 30, 2025 establishing the process for additional products to be added to the list of steel and aluminum...more

Torres Trade Law, PLLC

Understanding the U.S. Bureau of Industry and Security’s Entity List and Unverified List: Overview and Removal Process

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) plays a critical role in protecting U.S. national security and advancing foreign policy objectives through its regulation of U.S. exports. Two...more

Frost Brown Todd

New Restrictions on Vehicle Connectivity Systems and Automated Driving Systems with Links to China and Russia

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On January 16, 2025, the Bureau of Industry and Security (BIS) introduced significant changes to 15 CFR Part 791 focused on mitigating national security risks associated with information and communications technology and...more

Baker Botts L.L.P.

Justice Department Declines Prosecution of U.S. Contractor for Export Control Violations of Rogue Employee

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For only the second time under its updated voluntary self-disclosure program, the U.S. Justice Department decided not to prosecute Universities Space Research Association after the company self-disclosed criminal violations...more

Sheppard Mullin Richter & Hampton LLP

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

WilmerHale

The United States and Singapore Signal More Robust Export Control Enforcement

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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

Troutman Pepper Locke

Inside New Commerce Tech Restrictions: Mitigation Strategies

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The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward....more

Sheppard Mullin Richter & Hampton LLP

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

Mintz - Antitrust Viewpoints

House Select Committee Publishes Report on DeepSeek, as Commerce Imposes New AI Chip Export Restrictions — AI: The Washington...

On April 16, the House Select Committee on the Chinese Communist Party (CCP) published a report on the Chinese company DeepSeek’s AI model with findings from the committee’s investigation into DeepSeek. The report...more

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more

Troutman Pepper Locke

Inside New Commerce Tech Restrictions: Key Risk Takeaways

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The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward. Originally...more

Sheppard Mullin Richter & Hampton LLP

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

Seyfarth Shaw LLP

Six Essential Tips for Government Contractors Engaging in International Sales

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In celebration of the release of the 6th edition of our Government Contracts Compliance Handbook, we are excited to share six essential tips for ensuring compliance in international sales. These tips are designed to help...more

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

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So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more

Davis Wright Tremaine LLP

Protect Yourself: U.S. Exporters Advised To Obtain End-Use and End-User Statements for All Exports, Including EAR99 Items

According to a trade press report, a Bureau of Industry and Security ("BIS"), Department of Commerce official speaking at the March 2025 BIS Update Conference on Export Controls and Policy recommended that U.S. exporters...more

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