News & Analysis as of

Export Controls U.S. Commerce Department

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

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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

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

White & Case LLP

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

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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

Baker Botts L.L.P.

AI Legal Watch: June 13

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The U.S. House of Representatives has passed, as part of a larger omnibus budget bill, a 10 year moratorium on regulation of AI by the states. If passed by the Senate, this provision would be one of the most significant...more

Womble Bond Dickinson

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

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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

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

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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

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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

Baker Botts L.L.P.

AI Legal Watch: May 20, 2025

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On May 13, the U.S. Commerce Department officially declared its intent to rescind and replace the AI Diffusion Rule issued during the final weeks of the Biden administration. Slated to go into effect on May 15, the rule had...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

Baker Botts L.L.P.

President Trump Pulls the Plug on Controversial AI Diffusion Rule

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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

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

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

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

Mintz - Antitrust Viewpoints

Commerce Department Investigates National Security of Semiconductors, and US Attorney Indicts AI CEO for Fraud — AI: The...

On April 1, the Department of Commerce (Commerce) launched a Section 232 investigation into the national security of semiconductor imports. On April 16, Commerce published a Request for Information (RFI) seeking public...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

White & Case LLP

Navigating NATO Procurement: Key Export Control Risks and Compliance Strategies for Nordic Companies

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As NATO procurement expands, Nordic companies must carefully navigate the intersection between NATO acquisition processes and multiple export control regimes, including those of the United States, the United Kingdom, and the...more

Troutman Pepper Locke

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

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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

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

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

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