News & Analysis as of

U.S. Commerce Department Reporting Requirements

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

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In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

Hone Maxwell

BE-10 Survey: What You Need To Know

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The BE-10 is a mandatory survey conducted by the Department of Commerce’s Bureau of Economic Analysis (BEA) every 5 years. Its purpose is to gather information on U.S. direct investments abroad, including financial and...more

Akerman LLP

BE-10 Benchmark Survey of U.S. Direct Investment Abroad Due May 30

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The Bureau of Economic Analysis (BEA) of the U.S. Department of Commerce is currently conducting its BE-10 Benchmark Survey of U.S. Direct Investment Abroad, which is due May 30, 2025. This survey stands as the most...more

Fenwick & West LLP

BE-10 Survey Filing Required for Certain U.S. Business Entities with Foreign Affiliates by May 30, 2025

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The U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) administers a survey every five years to collect information from U.S. persons that hold, directly or indirectly, at least 10% of the voting interest in a...more

Akin Gump Strauss Hauer & Feld LLP

Bureau of Economic Analysis’ Mandatory Form BE-10 Survey Deadline Approaches for a “Benchmark Year” for U.S. Persons with Direct...

The BE-10 Benchmark Survey of U.S. Direct Investment Abroad (the “BE-10 Survey”) is a mandatory survey conducted once every five years by the Bureau of Economic Analysis (BEA) of the U.S. Department of Commerce under the...more

DLA Piper

BE-10 Filing Required for US Companies with Ownership in Non-US Businesses: Due May 30, 2025

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The US Department of Commerce’s Bureau of Economic Analysis (BEA) conducts a mandatory BE-10 survey of US investments abroad every five years to produce key economic and statistical reports on the scale and effects of...more

BakerHostetler

Understanding the Mandatory BE-10 Survey of US Investments Abroad

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BEA administers the mandatory BE-10 survey to obtain key statistics on U.S. investment abroad for U.S. agencies, policymakers, business leaders, researchers, and the general public. Generally, any U.S. person that had a...more

Wilson Sonsini Goodrich & Rosati

Commerce’s Bureau of Economic Analysis Issues Mandatory Five-Year Survey of U.S. Direct Investment Abroad

The U.S. Department of Commerce's Bureau of Economic Analysis (BEA) recently issued its mandatory five-year benchmark survey to obtain data on direct investment abroad by U.S persons and businesses. The survey, known as the...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Filings Up, Pendency Down – USPTO 2024 Year in Review (& Early Thoughts for 2025)

With 2024 now in the rearview mirror, it’s a great time to take a look at the past year’s U.S. trademark prosecution and examination numbers – and consider where the U.S. Patent and Trademark Office (“USPTO”) may be heading...more

Skadden, Arps, Slate, Meagher & Flom LLP

National Security: Trump Orders Review of Export, Supply Chain, ‘Reverse CFIUS’ Rules

Several of President Donald Trump’s initial actions — from an executive order instituting a new artificial intelligence (AI) policy framework, to those directing the use of the U.S. military to provide border security, the...more

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more

Proskauer - New Media & Technology

Upcoming Changes to AI Regulation in the New Administration

With the second Trump Administration set to take power in January 2025, one can expect a pendulum swing in many aspects of technology policy. For example, while it is expected that President Trump will will continue efforts...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

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

Mayer Brown

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

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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

Wilson Sonsini Goodrich & Rosati

Commerce Proposes New Reporting Requirement for Advanced AI Developers and Cloud Computing Providers

Last week, the U.S. Department of Commerce’s (Commerce) Bureau of Industry and Security (BIS) released a Notice of Proposed Rulemaking (NPRM) outlining a new mandatory reporting requirement for large-scale AI developers and...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

Sheppard Mullin Richter & Hampton LLP

Commerce Updates Boycott Requester List

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

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - June 2024

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On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Antiboycott Regulations

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During the mid-1970’s, the U.S. adopted two laws that seek to counteract the participation of U.S. citizens in other nations’ economic boycotts or embargoes. These antiboycott laws are the 1977 amendments to the Export...more

Ankura

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

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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

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

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