News & Analysis as of

Export Controls U.S. Commerce Department

Hogan Lovells

BIS announces rescission of Biden-Era AI Diffusion Rule and issues new AI policy and guidance

Hogan Lovells on

At the same time that it potentially reduced licensing requirements on advanced computing items to a smaller group of countries by notifying industry that it started the process to rescind the AI Diffusion Rule, the U.S....more

Husch Blackwell LLP

BIS Announces Proposed Additions to Section 232 Steel and Aluminum Tariffs, Opens Public Comment Period

Husch Blackwell LLP on

On May 22, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) released a diverse list of 58 requests for new products to be added to the list of derivatives subject to the Section 232 tariffs on steel...more

Baker Botts L.L.P.

AI Legal Watch: May 20, 2025

Baker Botts L.L.P. on

On May 13, the U.S. Commerce Department officially declared its intent to rescind and replace the AI Diffusion Rule issued during the final weeks of the Biden administration. Slated to go into effect on May 15, the rule had...more

Sheppard Mullin Richter & Hampton LLP

Throwing Away the Toaster: Where AI Controls Are Now and May be Heading

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

WilmerHale

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

WilmerHale on

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

Alston & Bird

Commerce Rescinds AI Diffusion Rule, Releases Other Guidance Involving Overseas AI Chips

Alston & Bird on

On May 13, 2025, the Department of Commerce, Bureau of Industry and Security (BIS) officially rescinded the Framework for Artificial Intelligence Diffusion (“AI Diffusion Rule”), that was published during the last week of...more

Baker Botts L.L.P.

President Trump Pulls the Plug on Controversial AI Diffusion Rule

Baker Botts L.L.P. on

In a highly anticipated move, the Trump administration has announced that it will rescind and replace the AI Diffusion Rule issued by the Commerce Department during the last weeks of the Biden administration. Set to take...more

WilmerHale

The United States and Singapore Signal More Robust Export Control Enforcement

WilmerHale on

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

Troutman Pepper Locke

Inside New Commerce Tech Restrictions: Mitigation Strategies

Troutman Pepper Locke on

The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward....more

Mintz - Antitrust Viewpoints

House Select Committee Publishes Report on DeepSeek, as Commerce Imposes New AI Chip Export Restrictions — AI: The Washington...

On April 16, the House Select Committee on the Chinese Communist Party (CCP) published a report on the Chinese company DeepSeek’s AI model with findings from the committee’s investigation into DeepSeek. The report...more

Troutman Pepper Locke

Inside New Commerce Tech Restrictions: Key Risk Takeaways

Troutman Pepper Locke on

The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward. Originally...more

Sheppard Mullin Richter & Hampton LLP

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I

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

Mintz - Antitrust Viewpoints

Commerce Department Investigates National Security of Semiconductors, and US Attorney Indicts AI CEO for Fraud — AI: The...

On April 1, the Department of Commerce (Commerce) launched a Section 232 investigation into the national security of semiconductor imports. On April 16, Commerce published a Request for Information (RFI) seeking public...more

Davis Wright Tremaine LLP

Protect Yourself: U.S. Exporters Advised To Obtain End-Use and End-User Statements for All Exports, Including EAR99 Items

According to a trade press report, a Bureau of Industry and Security ("BIS"), Department of Commerce official speaking at the March 2025 BIS Update Conference on Export Controls and Policy recommended that U.S. exporters...more

White & Case LLP

Navigating NATO Procurement: Key Export Control Risks and Compliance Strategies for Nordic Companies

White & Case LLP on

As NATO procurement expands, Nordic companies must carefully navigate the intersection between NATO acquisition processes and multiple export control regimes, including those of the United States, the United Kingdom, and the...more

Troutman Pepper Locke

Trump Administration’s First Export Control Action – Reading the Tea Leaves

Troutman Pepper Locke on

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

BakerHostetler

[Podcast] Rev Up! Connected Vehicles: New National Security Law with Major Impact on Connected Vehicles and the Auto Supply Chain

BakerHostetler on

The topic is connected vehicles and the automotive supply chain and specifically how a new law that became effective on March 17, 2025, has major implications for automakers, auto suppliers, and investors and dealmakers doing...more

ArentFox Schiff

Taking Stock – Summary of BIS Actions From Fall 2024, and Peek at What Is Next Under the Trump Administration

ArentFox Schiff on

President Trump’s first months in office have been busy, but, in the export control world, we have been grateful for a brief respite from the mind-bending, hundreds-of-pages-long, industry-changing rules that the US...more

ArentFox Schiff

Summary of BIS’s December 5, 2024, Chip Controls

ArentFox Schiff on

On December 5, 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) promulgated an interim final rule (the December IFR) expanding its authority to restrict the dissemination of advanced chip technology...more

Orrick, Herrington & Sutcliffe LLP

New Duties on Imports from Canada, Mexico and Increased Duties on Chinese Imports – What Companies Need to Know

An update to our previous alert on new tariffs on Mexican and Canadian imports. Yesterday, as announced in several early February Executive Orders, the U.S. government imposed new duties on most imports from Canada and...more

Akin Gump Strauss Hauer & Feld LLP

Addressing the Threat to National Security from Imports of Timber, Lumber (Trump EO Tracker)

The executive order directs the Secretary of Commerce to conduct an investigation pursuant to Section 232 of the Trade Expansion Act of 1962 regarding “the effects on the national security of imports of timber, lumber, and...more

Husch Blackwell LLP

February 2025 Trade Law Update

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In Husch Blackwell’s February 2025 Trade Law Update you’ll learn about the following updates in international trade and supply chain law: •An update on U.S. Department of Commerce decisions - •U.S. International Trade...more

BakerHostetler

US Initiates an Investigation Under Section 232 of Trade Expansion Act on Effect of Copper Imports on National Security

BakerHostetler on

On Feb. 25, President Donald Trump signed an executive order directing the secretary of commerce to investigate the effects of copper imports on national security under Section 232 of the Trade Expansion Act of 1962. The...more

Akin Gump Strauss Hauer & Feld LLP

Addressing the Threat to National Security from Imports of Copper (Trump EO Tracker)

The executive order directs the Secretary of Commerce to conduct an investigation pursuant to Section 232 of the Trade Expansion Act of 1962 regarding “the effects on national security of imports of copper in all forms,”...more

Fox Rothschild LLP

Update on Outbound U.S. Investment Restrictions and Export Controls

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New U.S. investment and export control measures are shaping how businesses engage with foreign markets, particularly China. From limiting outbound investments to tightening export licenses, these evolving policies from the...more

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