On July 28, 2025, the National Security Division of the U.S. Department of Justice (DOJ) and the U.S. Department of Commerce, Bureau of Industry and Security (BIS), announced parallel criminal and civil-administrative export...more
8/6/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Guilty Pleas ,
National Security ,
Popular ,
Semiconductors
Section 232 investigations determine whether the targeted U.S. imports threaten to impair U.S. national security. At the conclusion of a Section 232 investigation (which can last for up to 270 days), the President must...more
4/22/2025
/ Bureau of Industry and Security (BIS) ,
Executive Orders ,
Government Investigations ,
Imports ,
National Security ,
Pharmaceutical Industry ,
Section 232 ,
Semiconductors ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department
The Commerce Department’s Bureau of Industry and Security (BIS) has released a pair of long-awaited rules that impose additional export controls on advanced computing integrated circuits (ICs) and artificial intelligence (AI)...more
On July 24, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) announced amendments to the U.S. Export Administration Regulations (EAR), expanding the reach of U.S. export jurisdiction over certain...more
7/30/2024
/ Amended Regulation ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Direct Product Rule ,
Iran ,
Jurisdiction ,
Russia ,
Software ,
Technology ,
Ukraine
The Bureau of Industry and Security (BIS) has published its spring 2024 regulatory agenda along with the rest of the Commerce Department. Of note is the continued focus on access to emerging technology, particularly relating...more
7/30/2024
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Cloud Computing ,
Data Centers ,
Export Controls ,
Exports ,
Final Rules ,
Innovative Technology ,
Interim Final Rules (IFR) ,
National Security ,
Proposed Rules ,
Regulatory Agenda ,
Reporting Requirements ,
Technology ,
U.S. Commerce Department
Earlier this week, the U.S. Bureau of Industry and Security (BIS) published new guidance on identifying and responding to parties that present a risk of diversion of export-controlled items to countries or entities of...more
Citing Russia’s “transition to a full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus today, including companies and individuals that continue to supply Russia’s...more
6/13/2024
/ Belarus ,
Belarus Sanctions ,
Biden Administration ,
Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
Export Controls ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Software ,
Software Developers ,
Technology Sector ,
Ukraine ,
US State Departments
Melissa Duffy and Trevor Coval contributed their thought leadership to the American Conference Institute’s 14th Annual Global Encryption, Cloud & Cyber Export Controls Conference, held in San Francisco on May 14-16. Melissa...more
5/22/2024
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Cloud Computing ,
Compliance ,
Department of Justice (DOJ) ,
Due Diligence ,
Export Controls ,
Exports ,
Hardware ,
IaaS ,
Know Your Customers ,
Military End Use ,
National Security ,
Popular ,
Proposed Legislation ,
Proposed Rules ,
Semiconductors ,
Sensitive Personal Information ,
Software ,
Supply Chain ,
Technology Sector
The United States imposed a new round of economic sanctions and export restrictions on Russia today, marking the second anniversary of Russia’s invasion of Ukraine and following the death of Russian opposition leader, Alexei...more
2/26/2024
/ Bureau of Industry and Security (BIS) ,
Business Operations ,
Doing Business ,
Economic Sanctions ,
Entity List ,
Export Bans ,
Financial Institutions ,
Investors ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Russia ,
Technology Sector ,
Ukraine
The Commerce Department’s Bureau of Industry and Security (BIS) has published new FAQs that offer further guidance on two interim final rules that went into effect in November 2023.
hese rules, for which the BIS is...more
1/12/2024
/ Anti-Terrorism Financing ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Electronic Export Information (EEI) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Interim Final Rules (IFR) ,
ITAR ,
Licenses ,
Semiconductors
The U.S. government is turning up the dial on its efforts to combat evasion of export controls and sanctions against Russia. The severe trade restrictions against Russia (and Belarus) have seen continuous escalation since...more
9/26/2023
/ Anti-Money Laundering ,
Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
FinCEN ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Suspicious Activity Reports (SARs) ,
Trade Restrictions ,
Ukraine
On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more
7/31/2023
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Disclosure ,
Disclosure Requirements ,
Enforcement ,
Export Controls ,
FinCEN ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblowers
On May 19, 2023, the Biden administration announced another major round of U.S. sanctions and export controls against Russia and Belarus in response to the ongoing war in Ukraine, in coordination with the G7 Leaders’ Summit...more
5/23/2023
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Corporate Counsel ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Foreign Direct Product Rule ,
G7 ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Tariffs ,
US Department of State
The U.S. Department of State (State Department) and U.S. Department of Commerce (Commerce Department), have recently previewed, proposed or finalized changes to relevant trade controls. These new regulatory updates include...more
1/18/2023
/ Amended Regulation ,
Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Directorate of Defense Trade Controls (DDTC) ,
Export Administration Regulations (EAR) ,
Export Controls ,
ITAR ,
National Security ,
Popular ,
Proposed Rules ,
Regulatory Agenda ,
U.S. Commerce Department ,
US Department of State
On October 7, 2022, the US Department of Commerce Bureau of Industry and Security (BIS) released two rules implementing new export controls on advanced computing and semiconductor manufacturing items in addition to new...more
10/24/2022
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Commerce Control List ,
ECCNs ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Investment ,
General Licenses ,
New Rules ,
Supply Chain ,
Technology Sector
CFIUS Executive Order Highlights Current Concerns Over Wide Range of Foreign Investments -
On September 15, 2022, President Biden issued an Executive Order (“EO”) on the interagency Committee on Foreign Investment in the...more
9/22/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Cybersecurity ,
Executive Orders ,
Export Controls ,
Foreign Investment ,
National Security ,
Popular ,
Supply Chain ,
Technology Sector
On September 9, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (BIS or Commerce) published a rule, sought by tech and telecom companies, and industry organizations, authorizing the release of certain...more
9/12/2022
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Huawei ,
National Security ,
New Rules ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
This alert summarizes the current state of trade measures and restrictions against both Russia and Belarus, following our last update on February 25, 2022....more
3/9/2022
/ Aircraft ,
Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
U.S. Commerce Department
The United States government, in partnership with allies and partners, issued new and expanded sanctions and trade controls in response to Russia’s continued invasion into Ukraine. These measures followed the sanctions that...more
On October 5, 2021, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published a final rule amending the Export Administration Regulations (EAR) to include new controls on genetic editing software and...more
10/6/2021
/ Biotechnology ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Commerce Control List ,
Critical Infrastructure Sectors ,
Cross-Border ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Foreign Investment ,
Life Sciences ,
Research and Development ,
Software