News & Analysis as of

National Security Bureau of Industry and Security (BIS)

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

Wiley Rein LLP

BIS Rescinds AI Diffusion Rule and Issues Guidance on Advanced Computing Integrated Circuits

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On May 12, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced the rescission of the previously issued Framework for Artificial Intelligence (AI) Diffusion Rule. The following day, May 13,...more

Akin Gump Strauss Hauer & Feld LLP

BIS Rescinds Its AI Diffusion Rule and Issues Compliance Guidance Regarding Advanced Computing Items

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a series of significant updates affecting export controls on advanced computing integrated circuits (ICs), artificial intelligence (AI)...more

Jenner & Block

Client Alert: What’s Next for the AI Diffusion Rule

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The Trump administration recently announced its intent to scrap the so-called AI diffusion rule, a complex regulation the Biden administration published in January to govern the global export of AI technology and maintain US...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

K2 Integrity

Quick Take: United States To Lift Sanctions Against Syria

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On 13 May 2025, U.S. President Donald Trump announced that his administration will start “restoring the normal relationship” with Syria’s new government and “ordering the cessation of sanctions against Syria.” While, at the...more

White & Case LLP

Trump Administration Initiates Section 232 Investigation on Commercial Aircraft, Jet Engines, and Parts

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On May 9, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) announced the initiation of an investigation into the effects on US national security of imports of commercial aircraft and jet engines and...more

Sheppard Mullin Richter & Hampton LLP

Onshoring Pharma Ops: Reading Recent EO and Policy Tea Leaves

Recently, underscoring a commitment to national security, the White House and the Food and Drug Administration (FDA) issued separate communications that aim to bolster domestic drug manufacturing while tightening oversight of...more

The Volkov Law Group

Voluntary Self-Disclosure Shields Universities Space Research Association from Prosecution by DOJ

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On April 30, 2025, the U.S. Department of Justice’s National Security Division (“NSD”) issued a formal declination of prosecution to the Universities Space Research Association (“USRA”) following the organization’s timely and...more

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

Troutman Pepper Locke

The Least Known Risk in the Energy Sector: The “ICTS” National Security Rules

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There are unprecedented risks and opportunities emerging for companies in the energy sector as the Trump administration’s priorities start to come into focus. Many of those are well-known to the industry. Here’s one that’s...more

Torres Trade Law, PLLC

Understanding the U.S. Bureau of Industry and Security’s Entity List and Unverified List: Overview and Removal Process

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) plays a critical role in protecting U.S. national security and advancing foreign policy objectives through its regulation of U.S. exports. Two...more

Frost Brown Todd

New Restrictions on Vehicle Connectivity Systems and Automated Driving Systems with Links to China and Russia

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On January 16, 2025, the Bureau of Industry and Security (BIS) introduced significant changes to 15 CFR Part 791 focused on mitigating national security risks associated with information and communications technology and...more

Baker Botts L.L.P.

Justice Department Declines Prosecution of U.S. Contractor for Export Control Violations of Rogue Employee

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For only the second time under its updated voluntary self-disclosure program, the U.S. Justice Department decided not to prosecute Universities Space Research Association after the company self-disclosed criminal violations...more

Sheppard Mullin Richter & Hampton LLP

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III

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

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

Sheppard Mullin Richter & Hampton LLP

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II

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

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...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

Fenwick & West LLP

The Continued Retreat: Commerce Secretary Announces Section 232 Investigations into Pharmaceuticals and Semiconductors

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Section 232 investigations determine whether the targeted U.S. imports threaten to impair U.S. national security. At the conclusion of a Section 232 investigation (which can last for up to 270 days), the President must...more

Alston & Bird

Commerce Seeks Comments on Section 232 Investigation of Semiconductors

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The Department of Commerce’s Bureau of Industry and Security (“BIS”) has initiated a Section 232 investigation of imports of semiconductors and semiconductor manufacturing equipment. According to the Federal Register notice...more

Alston & Bird

Commerce Seeks Comments on Section 232 Pharmaceutical Investigation

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Yesterday, April 16, 2025, the Bureau of Industry and Security (BIS), a bureau within the U.S. Department of Commerce, published a “Notice of Request for Public Comments on Section 232 National Security Investigation of...more

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