On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a recission of the Biden administration’s January 15, 2025 Artificial Intelligence Diffusion Interim Final Rule (“AI Diffusion...more
6/18/2025
/ Artificial Intelligence ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Due Diligence ,
ECCNs ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
IaaS ,
New Regulations ,
Regulatory Reform ,
Semiconductors ,
Trump Administration ,
United Arab Emirates (UAE)
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
2/5/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Data Centers ,
Data Security ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Interim Final Rules (IFR) ,
National Security ,
Popular ,
Regulatory Requirements ,
Semiconductors ,
Supply Chain ,
Technology Sector ,
Trump Administration
Although the Trump transition is well underway, the Biden administration made news in the national security space by announcing significant new export restrictions on semiconductor equipment and technology destined for the...more
12/18/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
ECCNs ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Interim Final Rules (IFR) ,
NPRM ,
PRC ,
Secretary of State ,
Semiconductors ,
U.S. Commerce Department
On June 12, 2024, the United States took several hard-hitting sanctions- and export control-related actions intended to intensify pressure on the Russian government and hamper Russia’s ability to continue to support its war...more
6/19/2024
/ Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
General Licenses ,
Information Technology ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Software ,
Supply Chain ,
U.S. Commerce Department
On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more
As discussed in our September 2023 Lawfare article, the Biden administration’s first-of-its-kind outbound investment review program seeks to limit outbound investments by U.S. investors in Chinese developers of certain...more
12/15/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
China ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Foreign Investment ,
Foreign Nationals ,
Investment ,
Semiconductors ,
Technology ,
U.S. Treasury
Continuing the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) efforts to bolster enforcement and compliance, on April 18, 2023, BIS issued a memorandum announcing significant changes to its voluntary...more
The United States took two significant actions last week to cement its stance that protecting human rights around the globe is a central U.S. national security and foreign policy interest in export control policy and...more
After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more
3/1/2022
/ Airspace ,
Asset Freeze ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
G7 ,
Popular ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
United States
After several years of foreign and domestic negotiations surrounding controls on intrusion software, the U.S. Department of Commerce’s Bureau of Industry & Security (BIS) published an interim final rule on October 21, 2021,...more
11/5/2021
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Corporate Counsel ,
Cybersecurity ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Popular ,
Software ,
The Wassenaar Arrangement
On April 29, 2021, the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the District of Massachusetts (collectively, “DOJ”) announced that DOJ entered into a precedent-setting...more
In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more
2/16/2021
/ China ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
Iran Sanctions ,
Maritime Transport ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Pentagon ,
Pipelines ,
Popular ,
Ransomware ,
Russia ,
SDN List ,
Trump Administration