News & Analysis as of

Interim Final Rules (IFR) Supply Chain China

WilmerHale

BIS Issues Export Control Compliance Requirements for Semiconductor Fabricators

WilmerHale on

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

King & Spalding on

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

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

Holland & Knight LLP

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

Holland & Knight LLP on

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

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

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

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

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

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

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