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Throwing Away the Toaster: Where AI Controls Are Now and May be Heading

Anyhow, on a possibly related note, on May 14, 2025, BIS announced that it will rescind the AI Diffusion Rule and that, until the time of the official recission, would not enforce the Biden-era regulation. Stop-Gap Stopped...more

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

The Persistence of (High Bandwidth) Memory: Semiconductor Manufacturing Equipment and Korean Semiconductor Manufactures Face...

On December 2, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) issued a new set of regulations targeting semiconductors manufacturing equipment (SME) and high-bandwidth memory (HBM) chips. The updates...more

At Long Last, Final Rule for Outbound Investment Regulations Published

On October 28, 2024, the U.S. Department of Treasury released a pre-publication version of its final rule containing the outbound investment regulations. The rule arrives a little over a year after Executive Order 14105,...more

China Semiconductor Export Regulations, Episode V – Updates and Corrections to the Advanced Computing and Semiconductor...

On March 29, 2024, BIS issued an interim final rule (IFR) updating and correcting its advanced computing and semiconductor regulations published in October 2023 (which we discuss here in Episode III). This marks the third...more

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