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Sweeping New Framework Expands BIS Export Controls on Advanced Computing ICs and AI Technologies

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its Framework for Artificial Intelligence Diffusion, an Interim Final Rule revising the Export Administration Regulations...more

Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software

On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more

Trump Administration 2.0 – International Trade and National Security Update

The incoming Trump administration is likely to continue the trend of strengthening export controls over AI and advanced semiconductors destined to China. During President-elect Donald Trump’s first term, the Bureau of...more

Not So Fast: Congress Doubles Statute of Limitations Period for U.S. Sanctions Violations in Foreign Aid Bill

Following months of delays and intense debate in Congress, President Biden signed H.R. 815 into law on April 24, 2024, which made headlines for funding $95 billion in military aid to Ukraine, Israel, and Taiwan, along with...more

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