News & Analysis as of

Interim Final Rules (IFR) Supply Chain

Guidepost Solutions LLC

Unlocking Opportunity: Navigating the New Data Center Validated End User Program

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a significant interim final rule (IFR) that has created both challenges and exciting opportunities for these operators. This IFR...more

WilmerHale

BIS Issues Export Control Compliance Requirements for Semiconductor Fabricators

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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

Morrison & Foerster LLP

BIS Issues Interim Final Rule on Artificial Intelligence Diffusion as Biden Exits

On January 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) that expands controls on advanced computing integrated circuits (ICs or chips) and model weights...more

King & Spalding

Department of Commerce Issues Export Controls on Advanced Computing Chips and Artificial Intelligence Models

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The Department of Commerce’s Bureau of Industry and Security released on January 13, 2025, an interim final rule to implement an export control framework for Artificial Intelligence Diffusion to protect U.S. national security...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

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

Morgan Lewis

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

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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

Pillsbury - Global Trade & Sanctions Law

Correcting and Clarifying Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On March 29, 2024, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) issued an interim final rule (“2024 IFR”) clarifying and correcting its October 2023 interim final rules on advanced...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

Holland & Knight LLP

Snitches Don't Get Stitches: New Rule Requires Supply Chain Disclosures

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The Federal Acquisition Regulatory Council (FARC) issued a new final interim rule requiring contractors to review their supply chain to ensure no companies, products or services they are providing the federal government or...more

Perkins Coie

New US Export Controls Target China’s Semiconductor and Supercomputer Sectors

Perkins Coie on

"As I told Congress in July, my north star at BIS is to ensure that we are appropriately doing everything in our power to protect our national security and prevent sensitive technologies with military applications from being...more

Wiley Rein LLP

Wireless Roundup (December 2021)

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Key Wireless Deadlines- FCC Requests Comment on Implementation of PSAP Do-Not-Call Registry: The Federal Communications Commission (FCC or Commission) seeks comment on a Further Notice of Proposed Rulemaking (FNPRM) intended...more

Wiley Rein LLP

Wireless Roundup (June 2021)

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Key Wireless Deadlines - Treasury Seeks Comment on Interim Final Rule Implementing Broadband Funding: Last month, the U.S. Department of Treasury (Treasury) issued an Interim Final Rule to implement the $350 billion...more

Morrison & Foerster LLP

Biden Administration Carries Forward Trump Era Executive Order Scrutinizing Imports And Sales Of Certain Communications Technology...

On March 22, 2021, the Department of Commerce (“Commerce”) interim final rule to implement provisions of Executive Order 13873 on Securing the Information and Communications Technology and Services (ICTS) Supply Chain became...more

WilmerHale

New Commerce Rule Covering ICTS Transactions Involving Foreign Parties

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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"

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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

Morgan Lewis

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

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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

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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 Department Publishes Interim Final ICTS "Foreign Adversary" Rules

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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

Stinson - Government Contracting Matters

DNI Apparently Has Granted DoD A Limited Temporary Waiver of Section 889 Implementation

Government contractors have been closely watching developments in the implementation of Section 889 of the National Defense Authorization Act for FY 2019, which bans government contractors’ use and provision of...more

Akin Gump Strauss Hauer & Feld LLP

Section 889(a)(1)(B): Five Things to Know About the Interim Rule and a Roadmap for Compliance

- Akin Gump is hosting a Webinar tomorrow, August 6, 2020, at 12:00 p.m. (EST) to discuss Section 889, the implementing regulations, and the grant and loan restrictions also effective August 13, 2020. - On July 14, 2020,...more

Stinson - Government Contracting Matters

Federal Contractors’ Compliance Responsibilities Just Got Easier, or Did They?

On July 14, 2020, the Federal Acquisition Regulatory (FAR) Council issued an interim final rule intended to clarify the scope and application of the requirements set forth in Section 889(a)(1)(B) of the FY2019 National...more

Akin Gump Strauss Hauer & Feld LLP

Commerce Department Extends Export Controls over Foreign-Made Items in Huawei’s Contract Manufacturing Supply Chain

- The U.S. Department of Commerce has published a highly complex and novel interim final rule extending the controls of the Export Administration Regulations (EAR) over foreign-made items in Huawei’s contract manufacturing...more

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