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
5/16/2025
/ Artificial Intelligence ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Export Controls ,
Exports ,
Interim Final Rules (IFR) ,
National Security ,
New Guidance ,
Popular ,
Semiconductors ,
Trump Administration ,
U.S. Commerce Department
The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more
5/6/2025
/ Business Entities ,
Compliance ,
Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
National Security ,
Non-Prosecution Agreements ,
Sanction Violations ,
Self-Reporting ,
Voluntary Disclosure
Recent actions by the Singapore and US governments following DeepSeek’s alleged use of restricted artificial intelligence (AI) chips signal more robust enforcement of export controls. Not only is Singapore stepping up its...more
4/29/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Enforcement Priorities ,
Export Controls ,
National Security ,
Risk Mitigation ,
Semiconductors ,
Singapore ,
Technology Sector ,
U.S. Commerce Department
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
4/18/2025
/ China ,
Electronic Devices ,
Executive Orders ,
Exports ,
Government Investigations ,
Imports ,
International Trade ,
Minerals ,
National Security ,
Pharmaceutical Industry ,
Section 232 ,
Semiconductors ,
Tariffs ,
Trump Administration
On February 1, President Trump issued two Executive Orders (EOs) announcing the imposition of a 25% tariff on products of Canada (10% on energy products) and Mexico, effective February 4. On February 3, the President...more
3/5/2025
/ Canada ,
China ,
Corporate Counsel ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
National Security ,
Tariffs ,
Trade Policy ,
Trump Administration ,
US Trade Policies
President Donald Trump issued two presidential proclamations on Monday, February 10, 2025, that make significant changes to the tariffs on steel (25%) and aluminum (10%) that the president initially imposed in his first term...more
On February 1, 2025, the Trump Administration announced that it would impose tariffs on imports of certain goods from Canada, Mexico and China, to be effective February 4, 2025. Although the Trump Administration reached...more
2/10/2025
/ Antitrust Investigations ,
China ,
Export Controls ,
Imports ,
International Trade ,
National Security ,
Tariffs ,
Trade Relations ,
Trade Retaliation ,
Trade Wars ,
Trump Administration ,
Unfair Competition ,
US Trade Policies
On January 13, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) released its export control titled “Framework for Artificial Intelligence Diffusion.” This new interim final rule creates a two-pronged...more
In the last few days of the Biden Administration, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a flurry of new, noteworthy rules targeting national security risks in the science and...more
2/6/2025
/ Artificial Intelligence ,
Biden Administration ,
Biotechnology ,
Bureau of Industry and Security (BIS) ,
Connected Cars ,
ECCNs ,
Export Controls ,
Final Rules ,
National Security ,
Regulatory Freeze ,
Semiconductors
On January 15, 2025, BIS issued an interim final rule controls targeting integrated circuits (“ICs”) fabricators. BIS is concerned that some IC designers have misrepresented the performance capabilities and intended end use...more
2/6/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Due Diligence ,
Entity List ,
Export Controls ,
Final Rules ,
Interim Final Rules (IFR) ,
National Security ,
Semiconductors ,
Supply Chain ,
Technology Sector
On January 14, 2025, BIS released the final rule for Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles (Connected Vehicle Rule). The Connected Vehicle Rule prohibits imports...more
2/6/2025
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Connected Cars ,
Export Controls ,
Final Rules ,
National Security ,
Russia ,
Supply Chain ,
Trump Administration ,
U.S. Commerce Department
On January 15, 2025, BIS issued an Interim Final Rule that amends the Export Administration Regulation (EAR) to address dual use export control concerns about biotechnology. ...more
2/6/2025
/ Artificial Intelligence ,
Biotechnology ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Food and Drug Administration (FDA) ,
Interim Final Rules (IFR) ,
International Trade ,
Life Sciences ,
National Security ,
Regulatory Requirements ,
Technology Sector
On October 28, the Biden Administration released its long-awaited final rule to restrict U.S. investment in China. This outbound investment regime, which is effective January 2, 2025, will impact all U.S. companies and...more
11/5/2024
/ Artificial Intelligence ,
Biden Administration ,
China ,
Compliance ,
Corporate Counsel ,
Final Rules ,
Foreign Investment ,
National Security ,
Outbound Transactions ,
Technology Sector ,
U.S. Treasury
As governments globally resort to more muscular uses of economic tools, such as sanctions and export controls for national security and foreign policy purposes, international trade has become increasingly complex. In this...more
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
7/29/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Colleges ,
Compliance ,
Due Diligence ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Federal Contractors ,
National Security ,
Popular ,
Russia ,
Ukraine ,
Universities