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US Export Controls on “AI Diffusion” Officially Paused, but New Guidance Elevates Risk for AI-Related Exports

On May 13, 2025, the Department of Commerce formally signaled its intention to rescind the Biden Administration’s Framework for Artificial Intelligence Diffusion (AI Diffusion Rule) two days before the January 2025 Interim...more

President Trump Announces Three New Section 232 Investigations After Suspending Reciprocal Tariffs, Excluding Certain Electronics,...

The Trump Administration has formally launched three separate national security investigations under Section 232 of the Trade Expansion Act of 1962 including on: 1) imports of semiconductors (including downstream electronic...more

China Imposes Series of Measures to Counter US Export Restrictions

China this past fall imposed an additional series of trade and other measures to counter actual and prospective trade measures by the United States with particular impact on semiconductors and raw materials, challenging the...more

Post-Election Trade Strategy for Businesses: Understanding the Landscape

President-elect Trump’s election victory has renewed the focus on international trade as a top-line concern for corporate executives. During the campaign, the president-elect expressed support for tariffs and other trade...more

BIS Issues Sweeping Additional Restrictions on Semiconductors and Advanced Computing, Entity List Designations

On December 2, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released its third round of export controls primarily targeting China’s attempts to create an “independent and controllable”...more

BIS Sets Higher KYC Standards for Companies and Universities Over Russia Diversion Concerns

On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more

Hiding in Plain Sight: New Ukraine and Israel Aid Package Includes Significant Changes to US Sanctions and Export Control Laws

On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

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