News & Analysis as of

Export Controls Final Rules

Wyrick Robbins Yates & Ponton LLP

The Justice Department’s New Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or...

On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more

Baker Botts L.L.P.

President Trump Pulls the Plug on Controversial AI Diffusion Rule

Baker Botts L.L.P. on

In a highly anticipated move, the Trump administration has announced that it will rescind and replace the AI Diffusion Rule issued by the Commerce Department during the last weeks of the Biden administration. Set to take...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

Baker Donelson

DOJ Issues Additional Guidance and Clarification on the Bulk Data Transfer Rule: What U.S. Businesses Need to Know

Baker Donelson on

On April 11, 2025, the Department of Justice's National Security Division (NSD) issued additional guidance to assist U.S. organizations in understanding and complying with the Data Security Program (DSP). As discussed in our...more

Troutman Pepper Locke

Inside New Commerce Tech Restrictions: Key Risk Takeaways

Troutman Pepper Locke on

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

ArentFox Schiff

BIS Issues Final Rule for Voluntary Self-Disclosure Procedures

ArentFox Schiff on

On Thursday, September 12, 2024, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule updating the agency’s policies on voluntary self-disclosures and the Guidance on Charging and Penalty...more

ArentFox Schiff

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

ArentFox Schiff on

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

ArentFox Schiff

BIS and DDTC Announce New Rules to Modernize Space-Related Export Controls

ArentFox Schiff on

On October 23, 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) and the US State Department’s Directorate of Defense Trade Controls (DDTC) issued a tranche of new rules to overhaul and modernize US...more

Perkins Coie

New US Commerce Prohibitions on Chinese and Russian Connected Vehicle Technology

Perkins Coie on

New security rules designed to protect the connected vehicle supply chain will take effect in March unless they are withdrawn. The U.S. Department of Commerce Bureau of Industry and Security (BIS) published the final rule...more

Wilson Sonsini Goodrich & Rosati

New BIS Rule Expands Export Controls and Due Diligence Requirements for Advanced Computing Integrated Circuits

As part of its ongoing efforts to thwart China's development of advanced computing technologies, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an interim final rule (the IFR) last month that...more

Morgan Lewis

Smartphones on Wheels: Commerce Issues Game-Changing Final Rule on Securing the ICTS Supply Chain in Connected Vehicles

Morgan Lewis on

The US Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule on January 16, 2025 that prohibits the import, sale, and manufacture of vehicles equipped with Vehicle Communication Systems (VCS)...more

Akin Gump Strauss Hauer & Feld LLP

Connected Vehicles Rule to Disrupt Supply Chain and Impose Compliance Obligations

On January 16, 2025, the Bureau of Industry and Security (BIS) published the Final Rule, prohibiting the import of “vehicle connectivity system” (VCS) hardware (including connected vehicles integrating that hardware) and the...more

Paul Hastings LLP

DOJ and CISA Issue Proposed Rules Regulating Export of Bulk Sensitive Data

Paul Hastings LLP on

The Department of Justice (DOJ) released a Final Rule restricting certain transfers of Americans’ sensitive personal data to identified countries of concern or covered individuals. The Final Rule continues to assert the DOJ...more

WilmerHale

Hic Sunt Dracones: Biden’s BIS Issues Last Minute Export Controls, Most of Which Appear to Escape Trump’s Regulatory Freeze

WilmerHale on

In the last few days of the Biden Administration, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a flurry of new, noteworthy rules targeting national security risks in the science and...more

WilmerHale

BIS Issues Export Control Compliance Requirements for Semiconductor Fabricators

WilmerHale on

On January 15, 2025, BIS issued an interim final rule controls targeting integrated circuits (“ICs”) fabricators. BIS is concerned that some IC designers have misrepresented the performance capabilities and intended end use...more

WilmerHale

BIS Issues the Final Connected Vehicles Rule, But Trump’s Recent Presidential Action Throws Implementation into Question

WilmerHale on

On January 14, 2025, BIS released the final rule for Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles (Connected Vehicle Rule). The Connected Vehicle Rule prohibits imports...more

Wilson Sonsini Goodrich & Rosati

The Busy Lawyer’s Guide to the New “Data Export Control” Rules

On January 8, 2025, the U.S. Department of Justice (DOJ) published final rules (the Final Rules) to prohibit or restrict transactions by U.S. persons that could result in access to sensitive data by persons associated with...more

Foley Hoag LLP

Understanding the U.S.’s New Outbound Investment Rules - January 2025

Foley Hoag LLP on

Effective in January 2025, the U.S. Department of the Treasury issued a final rule (colloquially known as “Reverse CFIUS”) implementing the Outbound Investment Program, which prohibits U.S. persons from making certain...more

Sheppard Mullin Richter & Hampton LLP

Data, Deals, and Diplomacy, Part III: DOJ Issues National Security Final Rule with New Data Compliance Obligations for...

On January 8, 2025, the Department of Justice (“DOJ”) published its final rule addressing Executive Order (E.O.) 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Eversheds Sutherland (US) LLP

New BIS rule on connected cars: Prohibitions on technology from Russia and China

On January 16, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule prohibiting the sale or import into the United States of passenger vehicles containing certain hardware or...more

DLA Piper

Commerce Department Unveils New Rules on Responsible Diffusion of Artificial Intelligence Technology

DLA Piper on

During its last week before the inauguration, the Biden Administration issued significant and complex new export controls on semiconductors and related technology for artificial intelligence (AI) applications worldwide. These...more

Hogan Lovells

U.S. BIS final rule prohibits imports, sales of connected vehicles and systems with China or Russia nexus

Hogan Lovells on

On January 14, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) published the Final Rule addressing national security risks associated with connected vehicle technologies. The final rule, which...more

Vinson & Elkins LLP

Sweeping New Framework Expands BIS Export Controls on Advanced Computing ICs and AI Technologies

Vinson & Elkins LLP on

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its Framework for Artificial Intelligence Diffusion, an Interim Final Rule revising the Export Administration Regulations...more

Akin Gump Strauss Hauer & Feld LLP

America First Trade Policy

Requires a variety of reports and recommendations to be delivered to the President by April 1, 2025: on the causes of the persistent trade deficit, how to establish the External Revenue Service, unfair foreign trade...more

Eversheds Sutherland (US) LLP

New export controls on AI model weights and advanced computing integrated circuits -- supply chain complexity increases

On January 15, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) published an interim final rule (IFR) that imposes new controls on advanced computing integrated circuits (Advanced ICs) and certain...more

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