News & Analysis as of

National Security Export Controls

A&O Shearman

AI diffusion rule rescinded; policy guidance for advanced integrated circuits and commodities issued

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The U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced on May 13, 2025, its plans to rescind the Artificial Intelligence Diffusion Framework (the Rule), the Biden-era regulation that imposed a...more

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

K&L Gates LLP

Historic US Presidential Visit to the Middle East

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The President of the United States, Donald Trump, recently concluded a landmark tour of the Gulf Cooperation Council (GCC) visiting Saudi Arabia, Qatar, and the United Arab Emirates (UAE). This was his first official...more

Mintz - Antitrust Viewpoints

President Trump Signs AI Deepfake Act into Law and House Passes AI Measures — AI: The Washington Report

On May 19, President Trump signed the TAKE IT DOWN Act into law, which criminalizes the publication of non-consensual intimate imagery (NCII), including AI-generated deepfakes. The TAKE IT DOWN Act is the first US law to...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

BakerHostetler

A Refocused China Initiative: DOJ’s New White Collar Enforcement Strategy

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On May 12, 2025, Matthew Galeotti, Head of the Department of Justice’s (DOJ) Criminal Division, unveiled a comprehensive white collar enforcement strategy titled “Focus, Fairness, and Efficiency in the Fight Against...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

Wyrick Robbins Yates & Ponton LLP

The Justice Department’s New Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or...

On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more

Miles & Stockbridge P.C.

Lifting Sanctions On Syria: A Preview of the Process

President Donald Trump announced Tuesday during his trip to the Middle East that his administration would lift U.S. sanctions on Syria. Since the shock collapse of Bashar al-Assad’s regime in Syria late last year, the...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

Morrison & Foerster LLP

DOJ Issues Declination in Corporate Export Control Violations Matter

On April 30, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced its second-ever public declination under its updated corporate voluntary self-disclosure (VSD) policy when it declined to charge...more

Baker Botts L.L.P.

President Trump Pulls the Plug on Controversial AI Diffusion Rule

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In a highly anticipated move, the Trump administration has announced that it will rescind and replace the AI Diffusion Rule issued by the Commerce Department during the last weeks of the Biden administration. Set to take...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

Faegre Drinker Biddle & Reath LLP

DOJ National Security Division Issues Second Declination Since Issuance of Revised Corporate Enforcement Policy

On April 30, 2025, the National Security Division (NSD) of the Department of Justice (DOJ) announced the declination of prosecution against the Universities Space Research Association (USRA), a federal government contractor,...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Sanctions Update: Further Sanctions Against Russia Introduced, More Syria Sanctions Lifted and First UK Prosecution for a...

The UK’s sanctions regimes remain dynamic as they continue to respond to geopolitical changes. In recent weeks, the UK has enhanced its Russia sanctions, despite the uncertain direction of the international sanctions on...more

Lowenstein Sandler LLP

Revising Missile Controls Is Necessary to Help Allies and Prevent New Nuclear States

As the presidential transition began in January 2025, President Biden promulgated a new National Security Memorandum (NSM) on missile technology exports to advance “the President’s goals of strengthening allied defense...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

WilmerHale

Voluntary Disclosure of Export Control Violations is Critical for Settling Criminal Liability, DOJ Action Shows

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The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more

Seward & Kissel LLP

DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

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Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...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

Baker Botts L.L.P. on

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

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