News & Analysis as of

Export Controls Bureau of Industry and Security (BIS) National Security

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

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

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

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

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

Troutman Pepper Locke

Trump Administration’s First Export Control Action – Reading the Tea Leaves

Troutman Pepper Locke on

On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more

Foley Hoag LLP - White Collar Law &...

Bureau of Industry and Security – 2025 Update Conference on Export Controls and Policy

The 2025 BIS Update Conference on Export Controls and Policy wrapped up last week. Here are three main takeaways: 1. China is the Priority: The top three U.S. export controls and enforcement priorities for the new...more

American Conference Institute (ACI)

[Event] 19th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance - April 30th - May 1st, Washington, DC

With unprecedented change and intensifying enforcement, now is the time to ensure your team is prepared for what’s ahead. Ensure that you don’t miss out on critical U.S. and international economic sanctions updates and the...more

Husch Blackwell LLP

Week Nine in Trade – First 100 Days of the New Administration

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On March 13, 2025, the State Department published a notice in the Federal Register designating all agency action with respect to international trade a “foreign affairs function” of the United States under the Administrative...more

BakerHostetler

[Podcast] Rev Up! Connected Vehicles: New National Security Law with Major Impact on Connected Vehicles and the Auto Supply Chain

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The topic is connected vehicles and the automotive supply chain and specifically how a new law that became effective on March 17, 2025, has major implications for automakers, auto suppliers, and investors and dealmakers doing...more

ArentFox Schiff

Qualms About Quantum: New Export Controls Advanced Tech Aligns US Policies With Allied Countries

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On September 6, 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) introduced an interim final rule that imposed worldwide export controls on slew of advanced technologies to align with the...more

ArentFox Schiff

Taking Stock – Summary of BIS Actions From Fall 2024, and Peek at What Is Next Under the Trump Administration

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President Trump’s first months in office have been busy, but, in the export control world, we have been grateful for a brief respite from the mind-bending, hundreds-of-pages-long, industry-changing rules that the US...more

ArentFox Schiff

BIS Implements Additional Due Diligence Measures for Front-End Fabricators and Outsourced Semiconductor Assembly and Test...

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This January 16 interim final rule by the US Department of Commerce’s Bureau of Industry and Security (BIS) imposes a broader license requirement on two types of parties: “front-end fabricators” and Outsourced Semiconductor...more

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