News & Analysis as of

Interim Final Rules (IFR) Foreign Adversaries

Morgan Lewis

Securing the ICTS Supply Chain: Commerce Issues Final Rules Pursuant to EO 13873

Morgan Lewis on

The US Department of Commerce (Commerce or DOC) on December 6, 2024 issued a final rule codifying its framework for reviewing Information and Communications Technology and Services (ICTS) transactions under Executive Order...more

Hogan Lovells

Commerce amends its IFR on Securing the ICTS Supply Chain to address “connected software”

Hogan Lovells on

On November 26, 2021, the Department of Commerce published a proposed rule to amend its Interim Final Rule on Securing the Information and Communications Technology and Services Supply Chain. The proposed rule adds a...more

WilmerHale

New Commerce Rule Covering ICTS Transactions Involving Foreign Parties

WilmerHale on

A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more

ArentFox Schiff

Commerce Department Signals Tough Approach on China Under Controversial Trump Tech Supply Chain EO

ArentFox Schiff on

The subpoena issuance suggests that the Biden Administration will continue the US Government’s assertive approach to China. The US Department of Commerce, on March 17, 2021, issued subpoenas on multiple Chinese companies...more

Jones Day

Commerce Department Rule Authorizes Review of ICTS Transactions Involving "Foreign Adversaries"

Jones Day on

The Situation: Later this month, transactions in the information and communication technology and services ("ICTS") sector that involve designated "foreign adversaries" will be subject to review by the U.S. Department of...more

White and Williams LLP

Department of Commerce Issues New Interim Final Rule on Securing the Information and Communications Technology and Services Supply...

White and Williams LLP on

n late January 2021, the U.S. Department of Commerce issued an Interim Final Rule (Interim Rule) that would empower the Department to prohibit, mitigate and unwind certain categories of transactions with certain foreign...more

Akin Gump Strauss Hauer & Feld LLP

Biden Administration Reviewing Comments on Interim Final ICTS Rule

Key Points - On January 19, 2021, the U.S. Commerce Department published an interim final rule (IFR) to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more

Morgan Lewis

Overview and Implications of the Interim Final Rule Implementing Executive Order 13873

Morgan Lewis on

Executive Order 13873 focused on securing the information and communications technology and services supply chain against transactions involving “foreign adversaries.” Companies in the information and communications...more

Goodwin

Commerce Department Moves to Protect the Supply Chain for Information and Communications Technology and Services

Goodwin on

On January 19, 2021, the U.S. Department of Commerce published an interim final rule (the “ICTS Rule”) under former President Trump’s Information and Communications Technology and Services Executive Order issued in May 2019....more

ArentFox Schiff

‘Foreign Adversaries’ In Tech Supply Chain May Be Under the Microscope

ArentFox Schiff on

The Information and Communications Technology and Services (ICTS) Rule, if implemented by the Biden Administration, would significantly impact companies that have an international nexus in a number of different sectors,...more

Husch Blackwell LLP

Commerce Publishes Interim Final Rule Addressing “Foreign Adversaries” In ICTS Supply Chain

Husch Blackwell LLP on

On January 19, 2021, the U.S. Department of Commerce (Commerce) published a long-awaited interim final rule to address the use of goods or services sourced from “foreign adversaries” in the U.S. supply chain for information...more

Husch Blackwell LLP

Commerce Department Publishes Interim Final ICTS "Foreign Adversary" Rules

Husch Blackwell LLP on

Key Point: New rules will impact the use of equipment and digital services sourced from China and other “foreign adversaries” in a wide variety of transactions and activities that potentially pose a risk to U.S. national...more

Snell & Wilmer

New Commerce Rule Injects Uncertainty Into Foreign Transactions Involving Information and Communications Technology

Snell & Wilmer on

On January 14, 2021, the U.S. Department of Commerce issued an interim final rule to address national security, economic security, and public health and safety concerns related to Information and Communications Technology and...more

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