News & Analysis as of

Export Administration Regulations (EAR)

Sheppard Mullin Richter & Hampton LLP

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

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

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...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

Seyfarth Shaw LLP

Six Essential Tips for Government Contractors Engaging in International Sales

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In celebration of the release of the 6th edition of our Government Contracts Compliance Handbook, we are excited to share six essential tips for ensuring compliance in international sales. These tips are designed to help...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

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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

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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

Alston & Bird

BIS Update Wrap: Lutnick Signals Dramatic Increase in Export Enforcement

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After three days of informational sessions on multiple regulatory and compliance topics, the Bureau of Industry and Security (“BIS”) wrapped up its annual update conference this week in Washington D.C.  Secretary of Commerce...more

ArentFox Schiff

BIS and DDTC Announce New Rules to Modernize Space-Related Export Controls

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On October 23, 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) and the US State Department’s Directorate of Defense Trade Controls (DDTC) issued a tranche of new rules to overhaul and modernize US...more

Benesch

Pragmatic Regulatory Compliance Programs for Geopolitical Risk

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Geopolitical risks to supply chains are top of mind across C-Suites but few say what it means. The term “geopolitical risk” has largely become a codeword for import, export, and economic sanctions compliance. The fast pace of...more

American Conference Institute (ACI)

[Event] 15th Forum on Global Encryption, AI, Cloud & Cyber Export Controls - March 26th - 27th, San Francisco, CA

As global trade policy evolves faster than ever, now is the time to connect with your peers, discover new strategies, and most importantly, hear from the regulatory agencies on the front lines of policy change. ACI’s 15th...more

Womble Bond Dickinson

International Trade in Goods and Technology: An Ever-Changing Regulatory Landscape

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Governments have long regulated international trade in goods, technology, and investment for purposes of revenue generation, economic policy, and national security....more

The Volkov Law Group

Flighttime Enterprises, Inc. and Employees Indicted Over Alleged Role in Facilitating Illegal Exports to Russia

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In one of the most significant enforcement actions involving the illicit export of aircraft components to Russia since the imposition of sweeping sanctions in response to the country’s invasion of Ukraine, the U.S. Department...more

Bass, Berry & Sims PLC

Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations

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On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil...more

Akin Gump Strauss Hauer & Feld LLP

President Trump Issues America First Investment Policy Refocusing CFIUS and Outbound Investment Approach

On February 21, 2025, President Trump issued the America First Investment Policy Memorandum, which emphasizes the U.S. commitment to a strong, open investment environment while reshaping the U.S. government’s policy towards...more

WilmerHale

BIS Issues Long-Awaited Export Controls on AI

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On January 13, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) released its export control titled “Framework for Artificial Intelligence Diffusion.” This new interim final rule creates a two-pronged...more

WilmerHale

BIS Increases Export Controls on Key Biotech Equipment

WilmerHale on

On January 15, 2025, BIS issued an Interim Final Rule that amends the Export Administration Regulation (EAR) to address dual use export control concerns about biotechnology. ...more

Hogan Lovells

U.S. Department of Commerce expands controls on advanced semiconductors and establishes new controls on closed AI model weights

Hogan Lovells on

The new interim final rule imposes new global licensing requirements for ECCNs 3A090.a, 4A090.a, and corresponding .z items; controls for closed AI model weights; updated data center validated end-user authorizations;...more

Morrison & Foerster LLP

BIS Issues Interim Final Rule on Artificial Intelligence Diffusion as Biden Exits

On January 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) that expands controls on advanced computing integrated circuits (ICs or chips) and model weights...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - January 29, 2025

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In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert summarizes...more

BakerHostetler

Current State of U.S. Export Controls in Response to the Russian Federation’s Invasion of Ukraine - As of January 29, 2025

BakerHostetler on

In a continued effort to hinder Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert...more

King & Spalding

Department of Commerce Issues Export Controls on Advanced Computing Chips and Artificial Intelligence Models

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The Department of Commerce’s Bureau of Industry and Security released on January 13, 2025, an interim final rule to implement an export control framework for Artificial Intelligence Diffusion to protect U.S. national security...more

Pillsbury - Global Trade & Sanctions Law

BIS Issues Interim Final Rule Establishing a Framework for Artificial Intelligence Diffusion

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR), establishing new export controls targeting advanced artificial intelligence (AI) chips and model...more

Vinson & Elkins LLP

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

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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

Faegre Drinker Biddle & Reath LLP

U.S. Department of Commerce Issues Interim Final Rule Implementing Its Framework for Artificial Intelligence Diffusion

On January 13, 2025, BIS issued an interim rule amending the EAR to, among other things, impose a new control on certain advanced AI model weights for certain advanced closed-weight dual-use AI models, and revise controls on...more

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