News & Analysis as of

Export Controls New Guidance

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

Loeb & Loeb LLP

China’s CAC Answers Questions on Cross-Border Data Transfer in April and May Guidance

Loeb & Loeb LLP on

China’s primary data regulator, the Cyberspace Administration of China (CAC), released two sets of Q&As with respect to exporting data from China, one in April and one in May. The questions were selected from those raised...more

Wiley Rein LLP

ATF Removes Restrictions on Imports of Simunition Training Rounds

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The Bureau of Alcohol, Tobacco, and Explosives (ATF) has removed restrictions on the importation of non-lethal marking rounds (also known as “training rounds” or “simunition rounds”). The move is expected to remove...more

Wiley Rein LLP

ATF Allows Importation of Dual-Use Firearm Barrels, Irrespective of Previous Status or Configuration

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The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has issued Ruling 2025-1, which loosens ATF’s policy with respect to the importation of firearm barrels. Specifically, the agency will now allow the importation of...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AI diffusion rule rescinded; policy guidance for advanced integrated circuits and commodities issued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

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

WilmerHale

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

WilmerHale on

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

Alston & Bird on

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

McDermott Will & Emery

Quarterly Sanctions Update | Q2 2025

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In the second quarter of 2025, EU and UK sanctions policy continued to take shape against a complex and shifting geopolitical backdrop. The European Union sharpened its focus on Russia’s ‘shadow fleet’ by proposing new...more

ArentFox Schiff

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

ArentFox Schiff on

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

Foley Hoag LLP

Publication of G7 Guidance to Prevent Diversion of Common High Priority List (CHPL) Items to Russia/Belarus

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CHPL analysis - On September 24, 2024, the G7 has updated its Export Control and Sanctions Evasions Guidance to provide assistance to industrial companies in order to prevent the diversion, notably through third countries,...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

IR Global

BIS Updates Freight Forwarder Guidance And Best Practices

IR Global on

The Bureau of Industry and Security (BIS) has recently published a guidance document on its new website aimed at helping freight forwarders and exporters uphold compliance with U.S. export controls and regulatory...more

Venable LLP

On Notice: BIS Issues Guidance on Agency Mechanisms for Identifying and Informing U.S. Entities of Export Diversion Risks

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Typically, the Bureau of Industry and Security (BIS) within the U.S. Department of Commerce administers export controls on end users by designating those persons on one of its public screening lists—e.g., the Unverified List,...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

The Volkov Law Group on

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

Fenwick & West LLP

BIS Endorses TIP Screening Tool as Heightened Diversion Risks Continue

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Earlier this week, the U.S. Bureau of Industry and Security (BIS) published new guidance on identifying and responding to parties that present a risk of diversion of export-controlled items to countries or entities of...more

The Volkov Law Group

BIS Releases Updated Guidance for Freight Forwarders

The Volkov Law Group on

On March 28, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released updated guidance to freight forwarders specifically outlining their responsibilities under the aegis of the Export...more

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

BakerHostetler on

The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

McDonnell Boehnen Hulbert & Berghoff LLP

The USPTO's Guidance on Use of AI-based Tools in Practice

Since President Biden issued his Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, the U.S. Patent and Trademark Office has been investigating the potential pitfalls of...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2024 - BIS Updates Freight Forwarder Guidance And Best Practices

The Bureau of Industry and Security (BIS) has recently published a guidance document on its new website aimed at helping freight forwarders and exporters uphold compliance with U.S. export controls and regulatory...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU Expands Restrictive Measures in 13th Russian Sanctions Package and Publishes Guidance

On 23 February 2024, the European Union (EU) adopted a 13th package of sanctions against Russia, imposing asset freezes on additional individuals and entities, expanding existing sectoral sanctions and further limiting...more

The Volkov Law Group

Biden Administration Issues New Guidance for Freight Forwarders

The Volkov Law Group on

New guidance from the Biden Administration mandates that freight forwarders are responsible for complying with trade sanctions and export compliance. On December 11, 2023, the Biden Administration released a 10-page sanctions...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

Ballard Spahr LLP on

On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

U.S. Department of Justice Issues Employer Guidance on Avoiding Discrimination When Complying With Export Control Laws

A recent employer fact sheet from the U.S. Department of Justice’s (DOJ) Civil Rights Division highlights an area of exposure for employers related to document requests in connection with export compliance assessments....more

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