The United States has taken a historic step by terminating the Syria Sanctions Program, marking the most significant shift in U.S. foreign policy towards Syria since the fall of the Assad regime. In our earlier post, we...more
7/22/2025
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
Regulatory Reform ,
Sanctions ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
UK
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
5/19/2025
/ AI Act ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Export Controls ,
National Security ,
Popular ,
Regulatory Reform ,
Rulemaking Process ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
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 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 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
4/24/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
Export Administration Regulations (EAR) ,
Export Controls ,
National Security ,
Regulatory Reform ,
Russia ,
Semiconductors ,
Technology Sector ,
Trump Administration ,
U.S. Commerce Department
On April 16, 2025, the Department of Commerce announced that it initiated an investigation on April 1, 2025, under Section 232 of the Trade Expansion Act, into imports of semiconductors, semiconductor manufacturing equipment...more
4/17/2025
/ Bureau of Industry and Security (BIS) ,
Customs ,
Foreign Trade Regulations ,
Imports ,
Investigations ,
National Security ,
Regulatory Requirements ,
Section 232 ,
Semiconductors ,
Supply Chain ,
Tariffs ,
Technology Sector ,
Trade Policy ,
Trade Relations ,
Trump Administration ,
U.S. Commerce Department ,
WTO
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
12/23/2024
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Commerce Control List ,
Export Controls ,
Exports ,
Foreign Direct Product Rule ,
Manufacturers ,
National Security ,
Semiconductors ,
Technology Sector
You have always dreamed of going to space. All of us have at some point or another. And the only thing standing between you and that dream were overly-restrictive commodity and technology export licensing requirements on...more
In a land before time (technologically speaking . . . so, like, the mid-nineties), the most basic software encryption functions were controlled under the U.S. International Traffic in Arms Regulations. The then-current...more
Pull quote: “Every export—every single one—has a related financial transaction”
You are a banker. You do bankery things. You look at the ledgers, you tot up the numbers, you manage the accounts. Maybe you make loans,...more
This week of September 16, Paris will play host to the biggest spectacle of the year (sorry, Olympics), the World Space Business Week. Attendees will come from around the world to discuss advancements in commercial space and...more
9/16/2024
/ AUKUS ,
Australia ,
Bureau of Industry and Security (BIS) ,
Department of Defense (DOD) ,
Directorate of Defense Trade Controls (DDTC) ,
Export Controls ,
Exports ,
Infrastructure ,
ITAR ,
Satellites ,
Technology Sector ,
UK
As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide....more
7/16/2024
/ Antiboycott Requirements ,
Bureau of Industry and Security (BIS) ,
China ,
Enforcement Actions ,
Entity List ,
Export Controls ,
Huawei ,
Licensing Rules ,
Self-Disclosure Requirements ,
Semiconductors ,
U.S. Commerce Department ,
Voluntary Disclosure
On June 27, 2024, the U.S. Department of Commerce, Bureau of Industry & Security (BIS) announced its first update to the boycott requester list. The list contains entities that have been reported by a U.S. person as having...more
On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including:
1. Expanding the scope of financial sanctions:...more
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
Export controls are the manifestation of foreign, economic, and national security policy, and the implementation of policy requires dynamic adjustment, a back-and-forth, a balance. So. on December 7, 2023, amid the tightening...more
You’d be forgiven for thinking this Global Trade Law Blog has become a Semiconductors News Blog, with all the recent updates we have published on semiconductor regulation in the past year or two. And yes, we concede the...more
The United States and its allies are aiming to choke off the supplies that support the last vestiges of Russian industry. On May 19, 2023, the Bureau of Industry and Security (BIS) released new regulations implementing...more
Between Russia’s invasion of Ukraine and growing U.S. tensions with China, U.S. export controls are in the spotlight like never before. As if regulators have not already made it clear enough, recent statements and actions...more
5/19/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Exports ,
Investigations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Semiconductors ,
Ukraine
It looks like the licensing restrictions on Huawei are trickling into effect.
Our sources indicate that, as early as February 27, all license applications for exports or transfers involving Huawei which were pending with...more
3/6/2023
/ 5G Network ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Huawei ,
License Applications ,
Semiconductors ,
Telecommunications
On Monday, February 13, 2023, the U.S. government will officially issue a stricter policy of denial for providing lower-tech items to Huawei.
Technological containment continues as the Netherlands and Japan move to impose...more
2/9/2023
/ Bureau of Industry and Security (BIS) ,
China ,
EU ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Direct Product Rule ,
Huawei ,
Japan ,
Licensing Rules ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
On January 5, 2023, President Biden signed into law S. 1294, the “Protecting American Intellectual Property Act of 2022”. The Act requires the president to report to Congress and impose sanctions on any foreign person or...more
1/19/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
China ,
Entity List ,
Export Controls ,
Foreign Entities ,
Foreign Persons ,
Intellectual Property Protection ,
National Security ,
New Legislation ,
Sanctions ,
Theft ,
Trade Secrets ,
Trade Wars
As you may have heard here (and here and here), in October 2022, the United States issued sweeping measures aimed at the semiconductor industry in China. The new regulations restrict the export of semiconductors and related...more
12/21/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Japan ,
Microchip Technology ,
Netherlands ,
New Regulations ,
Semiconductors ,
Supply Chain ,
WTO
Key Takeaways Background Since October 7, 2022, when the Bureau of Industry and Security (“BIS”) dropped 140 pages of regulations on the semiconductor industry, U.S. passport and green card holders working at Chinese chip...more
The Announcement On Friday, October 7, 2022, the U.S. Bureau of Industry and Security (BIS) released for public inspection (available ...) one hundred forty pages of regulations (which we’ll call “the Regulation” here) that...more
10/11/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Depositions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Microchip Technology ,
Proposed Regulation ,
Regulatory Agenda ,
Semiconductors ,
Technology