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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

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 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

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

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

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

Commerce Department Strengthens Semiconductor and Advanced Computing Controls

On October 17, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) published two interim final rules (“IFR’s”) covering advanced computing items, semiconductor manufacturing equipment, and items that...more

Commerce Continues its Focus on Antiboycott Compliance

On July 26, 2023, Matthew Axelrod, the Assistant Secretary for Export Enforcement, issued a memorandum on “Strengthening Antiboycott Reporting and Compliance.” The memorandum announced two new measures. First, the Commerce...more

Senate Bill Proposes to Curb Export Licenses and Impose “Flow Down” Entity List Restrictions

On June 22, 2023, Senators Rubio (R-FL) and Wicker (R-MS) – the top Republicans on the Select Committee on Intelligence and the Armed Services Committee, respectively – introduced S. 2170, the Depriving Enemy Nations of...more

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