News & Analysis as of

Public Comment Export Controls

Husch Blackwell LLP

BIS Publishes Process for Requesting Inclusion of Section 232 Derivatives

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The Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule effective April 30, 2025 establishing the process for additional products to be added to the list of steel and aluminum...more

Akerman LLP

Updated Advanced Computing and Semiconductor Manufacturing Export Controls Take Effect

Akerman LLP on

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

Williams Mullen

First Round of ITAR Restructuring Amendments Go Into Effect September 6, 2022

Williams Mullen on

​​​​​​​The Directorate of Defense Trade Controls (DDTC) has embarked on a series of revisions to the International Traffic In Arms Regulations (ITAR) to clarify and better organize the ITAR. The first round of revisions is to...more

Holland & Knight LLP

Public Input Requested on U.S.-EU Export Control Working Group Priorities

Holland & Knight LLP on

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) recently published a Request for Public Comments regarding the newly formed Export Control Working Group of the U.S.-European Union (EU) Trade and...more

Goodwin

Commerce to Impose Long-Anticipated Export Controls on Cybersecurity Items

Goodwin on

In an interim final rule issued October 21, 2021, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) announced new Export Administration Regulations (EAR) controls on “cybersecurity items,” including...more

Goodwin

Commerce Department Proposes New Export Controls On Gene-Editing Software That Will Also Expand The Scope Of Mandatory CFIUS...

Goodwin on

On Friday, November 6, 2020, the Commerce Department’s Bureau of Industry & Security (BIS) issued a Notice of Proposed Rulemaking (NPRM) seeking public comment regarding newly-proposed controls on certain software for...more

Husch Blackwell LLP

BIS Seeks Comments On Identifying “Foundational Technologies”

Husch Blackwell LLP on

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently published an Advanced Notice of Proposed Rulemaking (“ANPRM”) regarding the identification and review of controls for certain “foundational...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Proposes CFIUS Mandatory Filing Based on Export Licensing

- On May 21, 2020, Treasury published a Proposed Rule to align the CFIUS mandatory filing framework for transactions involving critical technologies with existing export-licensing requirements. - Under the Proposed Rule,...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

Akin Gump Strauss Hauer & Feld LLP

Commerce Offers 15-Day Comment Period on Huawei TGL and Extends Validity Until May 15, 2020

- BIS extended until May 15, 2020, the Temporary General License authorizing certain exports, reexports, and transfers to Huawei and other listed affiliates of specific types of items that are relevant to third parties. -...more

Wilson Sonsini Goodrich & Rosati

Artificial Intelligence Software Controlled for Export, Including to Foreign National Employees

On January 6, 2020, the U.S. Commerce Department's Bureau of Industry and Security (BIS) released an interim final rule controlling the export of certain artificial intelligence software relating to geospatial imagery...more

Skadden, Arps, Slate, Meagher & Flom LLP

Commerce Department Will Move Forward With More Stringent Export Controls for Certain Emerging Technologies

Through the Export Control Reform Act of 2018 (ECRA), which was enacted in August 2018, Congress directed the U.S. Department of Commerce to conduct an interagency review process to identify “emerging and foundational...more

Akin Gump Strauss Hauer & Feld LLP

BIS Publishes a Temporary Unilateral Control on a Type of Machine Learning Software for Automating Analyses of Geospatial Imagery...

Key Points - On January 6, 2020, BIS published an interim final rule to add a new worldwide (minus Canada) unilateral export control on a type of geospatial imagery software specially designed for training Deep...more

WilmerHale

CFIUS Publishes New Proposed Regulations

WilmerHale on

The US Department of the Treasury recently published for public comment two proposed regulations that will expand the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) and make substantive...more

Sheppard Mullin Richter & Hampton LLP

Clear for More Takeoffs: Now is the Time to Have Your Voice Heard on New Satellite and Launch Regulations

On March 8, the U.S. government signaled regulatory changes that may create new opportunities for international collaboration on satellite development, global sales of satellite and launch equipment, and even sharing launch...more

Akin Gump Strauss Hauer & Feld LLP

State and Commerce Open Public Comment Period on Rocket, Missile, Launch Vehicle, Spacecraft and Satellite Export Controls

• The Departments of State and Commerce are soliciting comments on USML Categories IV and XV and related entries on the CCL (e.g., 9x004, 9x515, 9x604). • This comment period is the first opportunity for industry to...more

Holland & Knight LLP

DOE Releases Response to Comments on LNG Export Study

Holland & Knight LLP on

On Dec. 28, 2018, the Office of Fossil Energy of the Department of Energy (DOE) filed a notice in the Federal Register indicating its response to the 19 public comments received on its study entitled Macroeconomic Outcomes of...more

Sheppard Mullin Richter & Hampton LLP

Comment Deadline Extended: Export Controls on Emerging Technologies

• Emerging technology sectors are being reviewed now for new export controls that could take effect in 2019 (list below). • You may submit comments on the criteria the U.S. government will use to determine what technologies...more

Jones Day

The Emerging List of "Emerging and Foundational Technologies"

Jones Day on

The Situation: On November 14, 2018, the U.S. Department of Commerce ("Commerce")'s Bureau of Industry and Security ("BIS") issued an advanced notice of proposed rulemaking ("Notice") that seeks public comments for defining...more

Pillsbury - Global Trade & Sanctions Law

U.S. Commerce Department Releases Proposed Rulemaking for Export Controls on Emerging Technologies

On November 19, 2018, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a proposed rulemaking seeking public comment on criteria for identifying emerging technologies that are essential to U.S....more

Wilson Sonsini Goodrich & Rosati

Emerging Technologies to Be Controlled for Export: Comments Due December 19, 2018

On November 19, 2018, the U.S. Commerce Department's Bureau of Industry and Security (BIS) released its advance notice of proposed rulemaking (ANPRM) to control the export of emerging technologies. Comments on the ANPRM are...more

Akin Gump Strauss Hauer & Feld LLP

Commerce Gives Industry 30 Days to Provide Comments Regarding Possible Export Controls over Emerging Technologies

• The Bureau of Industry and Security published a notice yesterday seeking public comments on how it should define and identify a wide variety of emerging technologies that are not now controlled for export, but should be...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Department of Commerce Solicits Comments Regarding Emerging Technologies That Are Essential to US National Security

On November 19, 2018, the Bureau of Industry and Security, U.S. Department of Commerce (BIS) published an advance notice of proposed rulemaking (ANPRM) soliciting comments on the criteria to be used to identify emerging...more

Sheppard Mullin Richter & Hampton LLP

The Little Regulation That Will Make a Big Change in How You Do Business: Department of Commerce to Establish New Export Controls...

Key Takeaways: • Emerging technology sectors will soon be subject to new export controls. • Affected sectors include biotech, computing, artificial intelligence, positioning and navigation, data analytics, additive...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - September 2018

ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more

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