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 May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more
6/12/2025
/ Bureau of Industry and Security (BIS) ,
CAATSA ,
CFIUS ,
Economic Sanctions ,
EU ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Reform ,
SDN List ,
Syria ,
Trump Administration ,
U.S. Treasury ,
UK
On May 28, 2025, the U.S. Court of International Trade (CIT) ruled that President Trump lacks authority under the International Emergency Economic Powers Act (IEEPA) to impose his most sweeping tariffs against U.S. trading...more
6/9/2025
/ Appeals ,
Appellate Courts ,
Canada ,
China ,
Constitutional Challenges ,
Court of International Trade ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Judicial Authority ,
Mexico ,
Retaliatory Tariffs ,
Section 232 ,
Section 301 ,
Statutory Interpretation ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On February 21, 2025, President Trump published a National Security Presidential Memorandum outlining his administration’s views on foreign investment and substantial changes to current regulatory regimes. The...more
2/26/2025
/ America First Trade Policy ,
Artificial Intelligence ,
CFIUS ,
China ,
Compliance ,
Economic Sanctions ,
Export Controls ,
Foreign Agents Registration Act (FARA) ,
Foreign Investment ,
Foreign Policy ,
National Security ,
Regulatory Requirements ,
Russia ,
Trump Administration
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
On March 22, 2021, the Department of Commerce (“Commerce”) interim final rule to implement provisions of Executive Order 13873 on Securing the Information and Communications Technology and Services (ICTS) Supply Chain became...more
4/2/2021
/ Biden Administration ,
CFIUS ,
China ,
Critical Infrastructure Sectors ,
Electronic Communications ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Foreign Investment ,
Imports ,
Interim Final Rules (IFR) ,
Internet ,
Market-Sharing ,
NDAA ,
Networks ,
Notice of Proposed Rulemaking (NOPR) ,
Software ,
Supply Chain ,
Technology Sector ,
Trump Administration ,
U.S. Commerce Department
On March 12, 2021, a U.S. district court granted a temporary injunction requested by the Hong Kong-listed, Chinese electronics giant, Xiaomi Corporation (“Xiaomi”). The injunction blocks the U.S. Department of Defense (“DoD”)...more
3/22/2021
/ Biden Administration ,
Department of Defense (DOD) ,
Executive Orders ,
Hong Kong ,
Injunctions ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Preliminary Injunctions ,
Prohibited Transactions ,
Regulatory Authority ,
Sanctions ,
SDN List ,
Technology Sector ,
Trump Administration ,
U.S. Treasury
On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued five new frequently asked questions (“FAQs”) that clarify the scope of Executive Order (“E.O.”) 13959, the basis for OFAC’s...more
Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more
As widely reported, the Standing Committee of the National People’s Congress (the “NPC”) completed its deliberation of and formally promulgated the Law of the People’s Republic of China on Safeguarding National Security in...more
The United States has for decades utilized its economic clout to pursue sanctions against rogue governments and regimes, terrorists, narcotics traffickers, and human rights abusers. Now, with roughly half a year left in his...more
Earlier this month, the May 1, 2020 Executive Order (EO) on Securing the U.S. Bulk-Power System (BPS) was issued, and we wanted to pass along the following comments/insights about such EO. We find that it is helpful first to...more
Heightened U.S. national security concerns and trade tensions with China have resulted in new and expanded U.S. regulations that have created barriers for Chinese buyers seeking to acquire assets in the U.S. A number of years...more
At a time of heightened concern about foreign ownership or control of U.S. telecommunication networks and supply chains, President Trump issued an Executive Order (“EO”) on April 4, 2020 formalizing the interagency Team...more
As we enter 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) may need time to catch its breath after an exceptionally busy year. 2019 showed us that the Trump Administration continues to rely on...more
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more
On August 13, 2018, President Trump signed into law the Foreign Investment Review Risk Modernization Act of 2018 (“FIRRMA”) as part of the John S. McCain National Defense Authorization Act for 2019 (“2019 NDAA”). FIRRMA is...more