News & Analysis as of

Interim Final Rules (IFR) National Security U.S. Commerce Department

WilmerHale

BIS Issues Long-Awaited Export Controls on AI

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On January 13, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) released its export control titled “Framework for Artificial Intelligence Diffusion.” This new interim final rule creates a two-pronged...more

DLA Piper

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

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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

Faegre Drinker Biddle & Reath LLP

U.S. Department of Commerce Issues Interim Final Rule Implementing Its Framework for Artificial Intelligence Diffusion

On January 13, 2025, BIS issued an interim rule amending the EAR to, among other things, impose a new control on certain advanced AI model weights for certain advanced closed-weight dual-use AI models, and revise controls on...more

Mayer Brown

US Department of Commerce Issues Interim Final Rule Designed to Protect American AI

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On January 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) titled “Framework for Artificial Intelligence Diffusion.” The IFR builds on a long series of...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

Kelley Drye & Warren LLP

Commerce Department Publishes Artificial Intelligence “Diffusion” Rulemaking

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) announcing (1) updated controls for advanced computing chips and associated license...more

Blank Rome LLP

BIS Issues Significant New Round of Semiconductor Export Controls: Six Notable Changes

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The U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) recently issued significant new export controls under the Export Administration Regulations (“EAR”) aimed at further restricting semiconductor...more

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

Dorsey & Whitney LLP

Commerce Department Adopts Sweeping Changes in U.S. Export Controls

Dorsey & Whitney LLP on

On September 6, the Bureau of Industry and Security (“BIS”) in the U.S. Commerce Department issued an interim final rule (“IFR”) under the Export Administration Regulations (“EAR”) to add new export controls on semiconductor,...more

Blank Rome LLP

BIS Issues New Export Controls Targeting GAAFET, Quantum, and Additive Manufacturing, and Ushers in New Age of Plurilateral Export...

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued an interim final rule (“IFR”) under the Export Administration Regulations (“EAR”) imposing licensing requirements for exports to all...more

Holland & Knight LLP

Major Export Controls Revisions and the AUKUS Trilateral Security Partnership

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The U.S. Department of Commerce and U.S. Department of State have been continuously easing restrictions on export-controlled trade between the United States, United Kingdom and Australia to foster technological innovation...more

Fenwick & West LLP

Access Control and Emerging Tech Remain Top Priorities in BIS Regulatory Agenda

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The Bureau of Industry and Security (BIS) has published its spring 2024 regulatory agenda along with the rest of the Commerce Department. Of note is the continued focus on access to emerging technology, particularly relating...more

Akerman LLP

Updated Advanced Computing and Semiconductor Manufacturing Export Controls Take Effect

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On October 17, 2023, the Commerce Department’s Bureau of Industry and Security (“BIS”) released two interim final rules (“IFRs”) that amended the Export Administration Regulations (“EAR”) to significantly expand export...more

K&L Gates LLP

US Government Revises Comprehensive Export Controls on Semiconductors and Semiconductor Manufacturing Equipment

K&L Gates LLP on

On 17 October 2023, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued two new Interim Final Rules (collectively, the Updated Rule) that significantly revise and expand controls under the US Export...more

Hogan Lovells

US intensifies export control restrictions on semiconductor and supercomputing activities

Hogan Lovells on

The Department of Commerce’s Bureau of Industry and Security issued two interim final rules to expand on the 7 October 2022 restrictions aimed at denying access to certain advanced semiconductors, semiconductor manufacturing...more

Eversheds Sutherland (US) LLP

Commerce Department offers guidance on new controls on US person activities supporting the development or production of integrated...

Recently, the US Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule imposing additional export controls on certain advanced computing and semiconductor manufacturing items and for...more

Goodwin

Sweeping New US Export Controls Target China’s Semiconductor Industry

Goodwin on

​​​​​​​In an interim final rule published on October 13, 2022, the US Commerce Department’s Bureau of Industry and Security (BIS) announced sweeping amendments to the Export Administration Regulations (EAR) that impose new...more

Holland & Knight LLP

Commerce Department Rolls Out Measures to Strengthen Export Controls on China

Holland & Knight LLP on

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an interim final rule on Oct. 7, 2022, placing unilateral export controls on certain advanced computing items and semiconductor manufacturing...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

BCLP

More End Use/End User Restrictions Coming from BIS

BCLP on

Adding to the challenges of implementing the expanded military end use/end user rule in Part 744.21 of the Export Administration Regulations (“EAR”), restrictions on transactions involving military-intelligence end uses and...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

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

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