On August 19, 2025, President Trump signed into law the Maintaining American Superiority by Improving Export Control Transparency Act (the “Export Control Transparency Act” or the “Act”). The law amends the Export Control...more
Criminals are not as smart as they think they are. There is nothing so unique that elevates a scheme into the ethereal world of brilliance. The schemes get to be “typical” and the means by which they are executed are often...more
DOJ’s initiation of its aggressive trade enforcement strategy is quickly unfolding — and the new strategy is a real and significant threat to all companies engaged in international trade. We are no longer in the era of FCPA...more
On July 28, the U.S. Department of Justice’s National Security Division and the Department of Commerce’s Bureau of Industry and Security (BIS) jointly announced resolutions of parallel criminal and administrative...more
On May 27, the Federal Communications Commission (FCC) opened two rulemaking proceedings aimed at foreign involvement in U.S. communications networks, particularly by countries identified as foreign adversaries, such as China...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) plays a critical role in protecting U.S. national security and advancing foreign policy objectives through its regulation of U.S. exports. Two...more
On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more
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
Just as the year started, the Department of Homeland Security (“DHS”) announced the addition of 37 companies to the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List, bringing the total number of entities on the list...more
The U.S. Commerce Department and other regulatory agencies published regulations at a furious pace as the Biden administration came to a close this month. These new regulations appear to be primarily aimed at restricting...more
On December 2, 2024, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) issued two new rules further restricting China’s capability to produce advanced semiconductors. One final rule (the “Entity List...more
On January 2, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) Export Enforcement published its 2024 Year in Review, spotlighting key accomplishments in protecting U.S. national security. In this...more
As global economic and geopolitical environments enter a new era, companies need to continuously develop and adjust their coherent global business strategies to secure and further expand business opportunities in all markets...more
In October 2024, the Bureau of Industry and Security (“BIS”) issued new guidance to financial institutions (“FIs”) on best practices for compliance with the Export Administration Regulations (“EAR”). This guidance outlines...more
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia. ...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
On July 18, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the U.S. Export Administration Regulations (EAR) so that certain technology and software...more
On June 20, the Department of Commerce’s Bureau of Industry and Security (BIS) for the first time banned a software and cybersecurity company using authority provided by June 2023’s “Protecting Americans’ Sensitive Data from...more
Proposed federal legislation known as the BIOSECURE Act is being considered in both the U.S. House of Representatives and the U.S. Senate....more
During 2023 both Congress and the Biden Administration repeatedly expressed the need to secure critical supply chains, particularly batteries that rely heavily on lithium and critical minerals sourced from China. Concerns...more
For the second year running, and in what may prove to be a regular process, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has significantly expanded export controls on specific semiconductor and...more
On October 25, 2023, the Bureau of Industry and Security (“BIS”) published interim final rules amending the Export Administration Regulations (“EAR”) to add/clarify new controls on semiconductor manufacturing equipment...more
On November 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held a public briefing to address industry questions concerning the latest export controls on advanced computing and semiconductor...more
1. BIS Releases Texts of New Chip Export Control Rules- Updating and expanding on rules issued last year, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released three rules on October 27 targeting...more
The new measures build on sweeping restrictions that the United States introduced in October 2022. On October 17, 2023 — just over a year after introducing extensive regulations aimed at restricting parties in China from...more