News & Analysis as of

Proposed Rules Bureau of Industry and Security (BIS) U.S. Commerce Department

Wiley Rein LLP

How the FCC’s Public Notice on Connected Vehicle Technologies Could Reshape the Agency’s Covered List

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The Federal Communications Commission (FCC) has proposed adding certain connected vehicle technologies to its list of equipment and services covered By Section 2 of the Secure Networks Act – an unprecedented step that, if...more

Husch Blackwell LLP

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

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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

Troutman Pepper Locke

Drone Alert! BIS Seeks Comments From Industry on How to Secure the Unmanned Aircraft Systems Supply Chain

Troutman Pepper Locke on

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM) on January 3, 2025, seeking public input to inform the potential development of a rule to secure...more

Holland & Knight LLP

New Export Control Rules Present Key Regulatory Changes for Space-Related Items, Activities

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Vice President Kamala Harris on Dec. 20, 2023, convened the National Space Council to discuss U.S. leadership in space. The U.S. Department of State and U.S. Department of Commerce were subsequently tasked to "review relevant...more

Sheppard Mullin Richter & Hampton LLP

Commerce Takes on AI: Recent Developments from BIS on AI

In two recent rules, the Department of Commerce, Bureau of Industry and Security (BIS) has begun to take significant steps to monitor, and potentially control access to, U.S. artificial intelligence (AI) technology. AI...more

Hinckley Allen

Executive Branch Continues to Take Steps to Regulate AI in Absence of Federal Legislation: Commerce Proposes New Mandatory AI...

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On September 11, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a proposed rule that would create a mandatory quarterly reporting requirement for U.S. persons and U.S. entities that...more

Holland & Knight LLP

BIS Proposes Rule to Secure Connected Vehicle Supply Chains from Foreign Adversary Threats: Rule Will Create New Compliance...

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The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued a Notice of Proposed Rulemaking (Proposed Rule) on Sept. 26, 2024, to address certain undue or unacceptable risks identified in Executive Order...more

Skadden, Arps, Slate, Meagher & Flom LLP

US AI Industry Reporting for Duty: BIS Rule Would Require Quarterly Filings for ‘Dual-Use’ AI Models and Computing Clusters

On September 11, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published a proposed rule that would require U.S. persons to report certain activities related to the development or acquisition of...more

Dorsey & Whitney LLP

Commerce Department Proposes Reporting Requirements for Certain Artificial Intelligence Models and Computing Clusters

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In a notice published on September 9, 2024, announcing a proposed rule and request for comment (“Proposed Rule”), the U.S. Department of Commerce called for new reporting requirements for the development of certain advanced...more

Baker Botts L.L.P.

U.S. Government Proposes Reporting Requirements on the Development, Acquisition or Possession of Advanced AI Models and Large...

Baker Botts L.L.P. on

The Department of Commerce’s Bureau of Industry and Security’s (“BIS”) newly proposed rule on advanced artificial intelligence (“AI”) models and computing clusters will require developers and owners of powerful AI models and...more

Orrick, Herrington & Sutcliffe LLP

Proposed AI Reporting Requirements Tracking the Development of Foundational AI Models: Key Takeaways for Companies

The Commerce Department’s Bureau of Industry and Security (BIS) has proposed a rule that would establish reporting requirements to track development of advanced artificial intelligence (AI) models, in accordance with...more

Blank Rome LLP

BIS Proposes Prohibitions on Connected Vehicles with Links to China and Russia: Nine Observations for Companies to Consider

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), on September 23, 2024, issued a notice of proposed rulemaking (“NPRM”) to curb national security and privacy risks associated with information and...more

Mayer Brown

US Department of Commerce Issues Proposal to Require Reporting Development of Advanced AI Models and Computer Clusters

Mayer Brown on

On September 9, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (BIS) released notice of a proposed rule to create a mandatory reporting requirement for artificial intelligence (AI)...more

ArentFox Schiff

Footnote Frenzy: Charting Out Commerce’s Proposed Expanded US Person and End Use Export Controls and Facial Recognition Controls

ArentFox Schiff on

On July 29, the US government proposed big changes to rules about supporting or exporting to foreign military, intelligence, and security entities. The US Department of Commerce’s Bureau of Industry and Security (BIS) is...more

Fenwick & West LLP

Access Control and Emerging Tech Remain Top Priorities in BIS Regulatory Agenda

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The Bureau of Industry and Security (BIS) has published its spring 2024 regulatory agenda along with the rest of the Commerce Department. Of note is the continued focus on access to emerging technology, particularly relating...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - Australia and United Kingdom License Exemptions on the Way!

Canada has long enjoyed International Traffic in Arms Regulations (ITAR) license exemptions and minimal controls for items subject to the Export Administration Regulations (EAR). What about some of our other friends, such as...more

Ankura

U.S. Department of Commerce Issues Proposed Rule Impacting AI and U.S. IaaS Providers to Counter Foreign Malicious Actors

Ankura on

On January 29, 2024, the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce issued a new proposed regulatory rule (the “Proposed Rule”), which will impose significant diligence, monitoring, and reporting...more

Mayer Brown

Commerce Considers ICTS-related Rules to Address Connected Vehicle Risks

Mayer Brown on

On March 1, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (“BIS”) published an Advance Notice of Proposed Rulemaking1 (the “Notice”) seeking public comments on potential regulation of the...more

Cozen O'Connor

U.S. Department of Commerce Proposes a New KYC Rule Applicable to U.S. IaaS Providers

Cozen O'Connor on

On January 29, 2024, the U.S. Department of Commerce’s (Department) Bureau of Industry and Security issued a notice of proposed rulemaking (Proposed Rule) that proposes a new Customer Identification Program (CIP) and other...more

Davis Wright Tremaine LLP

Commerce Department Proposes Cybersecurity/AI Reporting and "KYC" Requirements for Certain Cloud Providers

The U.S. Department of Commerce's ("Commerce") Bureau of Industry and Security ("BIS") has issued a proposed rule (the "Proposed Rule") that would impose significant diligence, reporting, and recordkeeping requirements on...more

Skadden, Arps, Slate, Meagher & Flom LLP

Know Your Cloud Customer: Commerce Department Proposes To Regulate Foreign Access to US IaaS Products

On January 29, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) released a proposed rule (Proposed Rule) that would require U.S. cloud services providers (a.k.a. Infrastructure as a Service, or IaaS,...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - February 14, 2024

Lowenstein Sandler LLP on

Teradyne, a Massachusetts-based supplier of semiconductor testing equipment, has reportedly pulled $1 billion of manufacturing equipment out of China in 2023 following export controls on advanced computing materials and...more

Morrison & Foerster LLP

BIS Proposes Rule to Address Challenges of Artificial Intelligence and Malicious Cyber-Enabled Activities

On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a proposed rule to prevent foreign actors from using U.S. cloud computing services for malicious cyber activities. The proposal...more

Kelley Drye & Warren LLP

Commerce Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

Kelley Drye & Warren LLP

BIS Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

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