On January 15, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) updating export controls on advanced computing semiconductors. This IFR seeks to ensure that...more
The Final Rule formalizes a new governmental system to monitor through a notification process and, when necessary, restrict investments in China that may be viewed as a national security risk.
The regulations have broad...more
11/8/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
Brownfield Properties ,
Bureau of Industry and Security (BIS) ,
China ,
Final Rules ,
Greenfield Projects ,
Investment ,
Joint Venture ,
Limited Partnerships ,
National Security ,
Notice of Proposed Rulemaking (NOPR) ,
Notifications ,
Popular ,
Risk Management ,
SDN List ,
Semiconductors ,
U.S. Treasury
On September 5, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule imposing significant new export controls on quantum computing, cryocooling systems, semiconductor...more
The outbound investment program will affect U.S. persons considering certain investments or other transactions involving China and specific industry sectors (e.g., semiconductors, artificial intelligence and quantum...more
7/16/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
China ,
Covered Entities ,
Covered Transactions ,
Foreign Investment ,
Investment ,
Limited Partnerships ,
National Security ,
Notice of Proposed Rulemaking (NOPR) ,
Prohibited Transactions ,
Proposed Regulation ,
U.S. Treasury
On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering...more
5/9/2024
/ AUKUS ,
Australia ,
Directorate of Defense Trade Controls (DDTC) ,
Exemptions ,
Export Controls ,
Exports ,
ITAR ,
Popular ,
Proposed Regulation ,
Proposed Rules ,
UK ,
US Department of State
The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the...more
Takeaways: On January 16, 2024, the Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) announced several updates to its Voluntary Self-Disclosure (VSD) process aimed at enhancing the program’s...more
On October 5, 2023, the National Archives Information Security Oversight Office (ISOO) released a joint notice to provide guidance on facility clearances for joint ventures (JVs) in the National Industrial Security Program...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
On August 9, 2023, President Biden issued an Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. The new Executive Order (EO) is the...more
If implemented by the U.S. government, the restrictions would regulate certain outbound investments by U.S. persons in countries of concern such as China.
The regulations may be established by an executive order,...more
7/27/2023
/ Artificial Intelligence ,
Biden Administration ,
CFIUS ,
China ,
Corporate Counsel ,
Executive Orders ,
FIRRMA ,
Foreign Investment ,
International Trade ,
Investment ,
NDAA ,
Outbound Transactions ,
Semiconductors
On March 22, 2023, the Department of Defense (DoD) published a proposed rule to amend Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.225-7048. This amendment would implement an additional export control...more
This post marks the second entry in our Year-in-Review series. For prior posts, click here. Few sectors have been more affected by the sanctions on Russia than the energy industry....more
On October 28, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued guidance on its October 7, 2022 interim final rule (Rule) that imposed new export controls on certain advanced computing...more
On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (the “Rule”) imposing sweeping new export controls targeting certain advanced computing integrated...more
On July 13, 2022, as part of a new pilot program, the Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued two open general licenses (“OGLs”) permitting certain reexports and retransfers of unclassified...more
Sanctions designations may require U.S. persons involved with sanctioned individuals to terminate existing contracts, including leases.
It is important for landlords to conduct thorough due diligence on prospective...more
On February 27, 2022, the U.S., UK, and EU announced their agreement that certain Russian banks would be delisted from the Belgian-based Society for Worldwide Interbank Financial Telecommunication (SWIFT). ...more
3/8/2022
/ Delisting ,
Economic Sanctions ,
EU ,
Financial Institutions ,
Financial Transactions ,
Foreign Relations ,
General Licenses ,
Military Conflict ,
Russia ,
SWIFT ,
UK ,
Ukraine
On February 24, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule effective immediately imposing sweeping export control restrictions against Russia in response to Russia’s...more
3/3/2022
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Licensing Rules ,
Military End Use ,
Russia ,
U.S. Commerce Department ,
Ukraine
Despite months of posturing and growing geopolitical tensions, Russia’s full-scale invasion of Ukraine this week was a shock to the global community. Western leaders have been swift and unanimous in their response, condemning...more
2/28/2022
/ Anti-Money Laundering ,
Asset Freeze ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
On February 24, 2022, in response to Russia’s attack on Ukraine, President Biden announced further sanctions on Russian individuals and entities. These measures are in addition to those already announced on February 22 and 23...more
On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have...more
2/25/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Treasury ,
Ukraine
On February 22 and 23, 2022, President Biden announced further sanctions in response to Russia’s invasion of Ukraine. These sanctions build upon the U.S. sanctions issued on February 21, 2022. Specifically, the additional...more
The Biden administration is moving to implement the new electric vehicle charging station programs and $7.5 billion in new federal funds provided by the Infrastructure Investment and Jobs Act.
In mid-December, the White...more
On October 21, 2021, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced an interim final rule (Interim Rule), which will amend the Export Administration Regulations (EAR) to add controls for the...more