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Commerce Department Publishes Artificial Intelligence “Diffusion” Rulemaking

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) announcing (1) updated controls for advanced computing chips and associated license...more

OFAC Issues New Determinations, Sanctions, Targeting Russian Energy and Petroleum

On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued significant new sanctions targeting Russia’s primary oil revenue sources, including sanctions against Public Joint...more

Treasury Issues Final Rule on Outbound Investments to China

On October 28, 2024, the Treasury Department issued its final regulations (the Final Rule) implementing new controls on outbound investments under Executive Order 14105, issued on August 9, 2024 by President Biden. This Final...more

Commerce, Treasury, and State Announce Measures Targeted at Further Restricting Russia and Belarus

On August 23, 2024, the U.S. Departments of Commerce, Treasury, and State published new restrictions on Russia aimed at further limiting its access to U.S. materials and international procurement networks for its military....more

New Export Control Compliance Resources for Academic Institutions

On August 14, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued two new resources for academic institutions to help them navigate and comply with export controls. These come in the form of a...more

BIS Proposed Rule Expands Scope of Military End Uses and Users

On July 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced revisions to the Export Administration Regulations (EAR) through a proposed rule revising certain restrictions on military end uses...more

BIS Proposes New Rule on Facial Recognition Systems

On July 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a proposed rule amending the Export Administration Regulations (EAR) by adding two new unilateral item controls covering...more

DOJ Announces New Corporate Whistleblower Awards Pilot Program

On Thursday, August 1st, the Department of Justice announced a new Corporate Whistleblower Awards Pilot Program to ​“uncover and prosecute corporate crime.” This new program incentivizes whistleblowers with potentially very...more

OFAC Publishes Guidance on Extension of Statute of Limitations and Recordkeeping Requirements

On July 22nd, 2024, OFAC published a guidance document regarding the 21st Century Peace through Strength Act’s extension of the statute of limitations for civil and criminal violations of the International Emergency Economic...more

BIS Issues Guidance on Addressing Export Diversion Risks

On July 10, the Department of Commerce’s Bureau of Industry and Security (BIS) published guidance on how to identify parties that present a heightened risk of diversion to Russia’s military-industrial sector, as well as...more

U.S. Treasury Department Issues Proposed Rule Expanding CFIUS Coverage of Real Estate Transactions Near Military Installations

On July 8, 2024, the U.S. Treasury Department (“Treasury”), as the lead agency of the Committee on Foreign Investment in the United States (“CFIUS” or ​“the Committee”), issued a proposed rule to expand the Committee’s...more

Statute of Limitations for Sanctions Violations Increased to Ten Years

On April 24, 2024, the 21st Century Peace Through Strength Act became law. Although the Act contains many key national security policies, including aid for Ukraine and Israel, one provision that has been overlooked is a...more

Commerce Initiates Rulemaking Targeting Foreign-Manufactured Technology Used In Connected Vehicles

On Thursday, February 29th, 2024, the Department of Commerce (“the Department”) announced an advance notice of proposed rulemaking (“ANPRM”), seeking public comments regarding new potential regulations to ​“secure and...more

2nd Anniversary of Ukraine Invasion Brings New Sanctions on Russia

On February 23, 2024, on the 2nd anniversary of Russia’s invasion of Ukraine, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced significant new sanctions, adding nearly 300 Russian and select...more

Commerce Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

BIS Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

BIS Hits Wabtec Corporation with $153,175 Civil Penalty for Antiboycott Violations

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (“BIS”) announced a settlement with Wabtec Corporation of $153,175 for violations of the antiboycott provisions of the Export Administration...more

Commerce Department Expands Russia and Belarus Controls, Implements Clarifying Changes

On January 25, 2024, the Commerce Department’s Bureau of Industry and Security (“BIS”) strengthened its existing controls under the Export Administration Regulations (“EAR”) against Russia and Belarus. Specifically, BIS is...more

BIS Clarifies Notification and Licensing Requirements for Updated Semiconductor, Advanced Computing Export Controls

On December 29, 2023, the Commerce Department’s Bureau of Industry and Security (BIS) issued Frequently Asked Questions (FAQs) concerning the agency’s recently updated semiconductor and advanced computing export controls. In...more

White House Broadens Restrictions on Russia by Authorizing Sanctions on Foreign Financial Institutions and Expanding the Import...

On December 22, 2023, President Biden signed Executive Order 14114, titled ​“Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” (EO 14114), with a focus on holding foreign financial...more

Commerce Department Proposes to Ease Licensing Requirements for Strategic Trade Authorization

On December 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a proposed rule to amend License Exception Strategic Trade Authorization (“STA”) within the Export Administration...more

House 90-Day Review Report Calls for “Win-At-All-Costs” Approach to Preventing PRC Access to Critical U.S. Technology

On December 7, 2023, the U.S. House of Representative’s Foreign Affairs Committee (House Committee) released a 90-day report (the Report) on the Commerce Department’s Bureau of Industry and Security (BIS). The report lays...more

Treasury Department Announces Largest Settlement in History and Severe Penalties Against Binance

On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more

Annual Report to Congress Proposes Counters to China’s Military-Civil Fusion Program

On November 14, 2023, the U.S.-China Economic & Security Review Commission (the Commission) published its annual report to Congress. The report covers a wide range of topics, including a detailed assessment of the state of...more

OFAC Enhances Sanctions on Russia and Its Procurement Networks Abroad

On November 2, 2023, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) unveiled new sanctions targeting Russia’s energy production, metals and mining, and defense procurement sectors. OFAC also continued...more

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