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Akin Intelligence - October 2023

Welcome to the October edition of Akin Intelligence. We continue to see bipartisan and international interest in artificial intelligence (AI) regulation. In the executive branch, agencies are working towards developing...more

Akin Intelligence - August 2023

Welcome back to Akin Intelligence: Hot AI Summer Edition! This month’s newsletter reflects the ongoing and increasing global activity around artificial intelligence (AI), including more proposed AI legislation and court...more

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Akin Intelligence - July 2023

Welcome to the July edition of Akin Intelligence. In this month’s AI news, the U.S. Senate receives member-only briefings on AI, U.S. states continue to debate and legislate on AI issues, the U.S. prepares new AI-related...more

Akin Intelligence - June 2023

Welcome back to Akin Intelligence! May featured major congressional hearings and state action in the United States, calls from industry and lawmakers for artificial intelligence (AI) regulation, and significant...more

DOJ Focuses on Corporate Crime Involving Sanctions Evasion, Export Controls Violations and Similar Economic Crimes

Key Points - On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more

BIS Has New Authorities to Impose Controls over Activities of US Persons in Support of Foreign Military, Security, or Intelligence...

Key Points - The Export Control Reform Act of 2018 has been amended to give BIS the authority to regulate services and other activities of U.S. persons, wherever located, when in support of foreign “military, security, or...more

BIS Imposes New Controls to Limit the Development and Production of Advanced Computing and Semiconductor Capabilities in China

The Commerce Department’s Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) to impose a series of significant new export controls designed to limit the development and production in...more

Commerce Department Publishes Updated Guidance on Antiboycott Enforcement Policies

Background - U.S. antiboycott laws, which are divided into two separate regimes administered by the U.S. Department of Commerce and the U.S. Department of the Treasury, prohibit U.S. persons from participating in foreign...more

BIS Announces Significant Changes to How It Administers Unverified and Entity Lists

Key Points - BIS amended the EAR to add a new criterion for placing a party on the Entity List: a sustained lack of cooperation by the host government to schedule and facilitate the completion of an end-use check of an...more

U.S. Department of Commerce Implements New Export Controls to Combat Malicious Cyber Activities

Key Points - On March 7, 2022, new U.S. export controls applicable to “cybersecurity items” took effect based on an interim final rule published by BIS on October 21, 2021 (the “Cyber Rule”). The controls under the Cyber...more

U.S. Government Imposes Expansive, Novel and Plurilateral Export Controls Against Russia and Belarus

Key Points - As part of highly coordinated U.S. government and allied and partner country responses to Russia’s further invasion of Ukraine, and Belarus’ enabling of it, BIS imposed on February 24, 2022, and March 2,...more

US Government Clarifies, Reorganizes and Renames Descriptions of How Foreign-Produced Items Outside the United States Are Subject...

Key Points - The U.S. Department of Commerce has reorganized and clarified the regulations describing when foreign-produced items outside the United States are and are not subject to the licensing and other obligations of...more

Commerce Proposes ICTS Changes for Connected Software Applications

Key Points - On November 26, 2021, the U.S. Department of Commerce issued a notice of proposed rulemaking related to “connected software applications” (“apps”) that aims to expressly incorporate transactions involving...more

The New PRC Anti-Foreign Sanctions Law

On June 10, 2021, the 29th session of the Standing Committee of the 13th National People’s Congress ("NPC") adopted China’s new Anti-Foreign Sanctions Law,1which took immediate effect. The new law provides legal grounds for...more

Biden Issues Executive Order Redirecting and Clarifying Scrutiny of Chinese Apps

Key Points - On June 9, President Biden signed an executive order (“EO”) revoking a series of Trump-era EOs targeting specific Chinese “connected software applications” (“apps”), including TikTok and WeChat. The EO calls...more

Biden Administration Revamps Sanctions Program Targeting Publicly Traded Securities of Designated Chinese Military Companies

On June 3, 2021, President Biden issued Executive Order 14032 (Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China) (“CMIC EO”) that modifies the Trump-era...more

Biden Administration Reviewing Comments on Interim Final ICTS Rule

Key Points - On January 19, 2021, the U.S. Commerce Department published an interim final rule (IFR) to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more

New Designations of Chinese Entities Impose Varying Restrictions

The U.S. government has recently imposed controls pertaining to “Communist Chinese Military Companies” (CCMCs or “1237 entities”); Chinese “Military End Users” (MEUs); and Chinese “Military-Intelligence End Users” (MIEUs)....more

Department of Energy Identifies “Foreign Adversaries” and Seeks Industry Input Regarding Implementation of Bulk-Power System...

- On July 8, 2020, the Department of Energy (DOE) published a Request for Information (RFI) concerning Executive Order 13920, “Securing the United States Bulk-Power System” (the “E.O.”). The E.O. authorizes the DOE to block...more

U.S. Agencies Issue Business Advisory Warning of Xinjiang-Related Supply Chain Exposure and OFAC Imposes Blocking Sanctions on...

- On July 1, the Departments of Commerce, Homeland Security, State, and the Treasury issued a joint advisory on the “Risks and Considerations for Businesses with Supply Chain Exposure to Entities Engaged in Forced Labor and...more

President Trump Establishes Framework to Ban the Use of Foreign-Sourced Equipment in the U.S. Electric Grid

- On May 1, 2020, President Trump issued an Executive Order (E.O.) aimed at curtailing the use of foreign-sourced electric equipment installed on the U.S. “bulk-power system,” which is commonly understood to mean the U.S....more

BIS Announces the Elimination of License Exception CIV, Expanded Licensing Requirements on Exports to Chinese, Russian, and...

- On April 28, 2020, the Bureau of Industry and Security of the U.S. Department of Commerce announced changes to the Export Administration Regulations (EAR) through three notices published on the Federal Register. The changes...more

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