News & Analysis as of

Interim Final Rules (IFR)

King & Spalding

Ninth Circuit Vacates Low-Wage-Index Policy

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On December 11, 2024, the Ninth Circuit struck down an HHS policy that boosted the wage index, and therefore the Medicare reimbursement rate, for hospitals in low-income communities in Kaweah Delta Health Care District v....more

Holland & Knight LLP

U.S. Strengthens Export Controls on Advanced Computing Items, Semiconductor Manufacturing Items

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The U.S. Bureau of Industry and Security (BIS) on Dec. 2, 2024, issued a Final Rule, "Additions and Modifications to the Entity List; Removals From the Validated End-User (VEU) Program" (Final Rule), and an Interim Final Rule...more

Morrison & Foerster LLP

In its Twilight, Biden Administration Adopts More Export Controls to Restrict China’s Ability to Produce Advanced Semiconductors

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Although the Trump transition is well underway, the Biden administration made news in the national security space by announcing significant new export restrictions on semiconductor equipment and technology destined for the...more

Akin Gump Strauss Hauer & Feld LLP

Akin Intelligence - September/October 2024

Welcome to the Akin Intelligence September-October recap. Around the one-year anniversary of the AI Executive Order, the White House announced that agencies had carried out their directives. Members of Congress introduced a...more

Blank Rome LLP

BIS Issues Significant New Round of Semiconductor Export Controls: Six Notable Changes

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The U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) recently issued significant new export controls under the Export Administration Regulations (“EAR”) aimed at further restricting semiconductor...more

Morgan Lewis

Securing the ICTS Supply Chain: Commerce Issues Final Rules Pursuant to EO 13873

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The US Department of Commerce (Commerce or DOC) on December 6, 2024 issued a final rule codifying its framework for reviewing Information and Communications Technology and Services (ICTS) transactions under Executive Order...more

Faegre Drinker Biddle & Reath LLP

U.S. Commerce Department Strengthens Export Controls to Restrict China’s Semiconductor Production

Background - On December 2, 2024, BIS announced two new rules under the EAR targeting the PRC’s ability to produce “advanced-node” semiconductors, including advanced-node integrated circuits (ICs), which can be used in...more

American Conference Institute (ACI)

The Future of Plurilateral Agreements: Compliance Considerations

The evolution of critical and emerging technologies continues to affect how the United States and its international allies and partners uniformly protect against national security threats. For industry, the strengthening of...more

Bracewell LLP

PRG 2024 Post-Election Pulse Check: Hydrogen

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E. Dee Martin, partner and co-head of Bracewell’s Policy Resolution Group, and Rebecca Brown, a PRG principal, discuss the future of the hydrogen industry during the second Trump administration....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

Akin Gump Strauss Hauer & Feld LLP

First Significant Changes in Over a Decade to US Export Controls on Space-Related Items and Activities

U.S. export controls on space-related items were last significantly revised in 2014. Since then, the industry has continued to evolve towards a wider range of public-private partnerships and purely commercial activities,...more

Hogan Lovells

BIS and DDTC issue rules to amend U.S. space-related export controls

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On October 17, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security and the State Department’s Directorate of Defense Trade Controls issued rules to modernize space-related export controls that aim to...more

Adams and Reese LLP

International Compliance Digest - September 2024

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New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

Husch Blackwell LLP

OFAC Issues Guidance Extending Statute of Limitations to 10 Years

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On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50, div. D. Part of the Act included a provision extending the statute of limitations for civil and criminal...more

King & Spalding

Ten-Year Statute of Limitations for Sanctions Violations Update

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As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more

Mayer Brown

BIS Adopts Additional Controls on Quantum, Semiconductor and Additive Manufacturing Technologies in Concert with International...

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On September 6, 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) issuing new export controls on quantum computing, semiconductor, and other advanced technology,...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

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OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

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In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control (“OFAC”) issue a notice changing U.S. sanctions – promulgating a new sanctions program or updating the designation of a...more

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Dorsey & Whitney LLP

Commerce Department Adopts Sweeping Changes in U.S. Export Controls

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On September 6, the Bureau of Industry and Security (“BIS”) in the U.S. Commerce Department issued an interim final rule (“IFR”) under the Export Administration Regulations (“EAR”) to add new export controls on semiconductor,...more

Blank Rome LLP

BIS Issues New Export Controls Targeting GAAFET, Quantum, and Additive Manufacturing, and Ushers in New Age of Plurilateral Export...

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued an interim final rule (“IFR”) under the Export Administration Regulations (“EAR”) imposing licensing requirements for exports to all...more

Holland & Knight LLP

Major Export Controls Revisions and the AUKUS Trilateral Security Partnership

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The U.S. Department of Commerce and U.S. Department of State have been continuously easing restrictions on export-controlled trade between the United States, United Kingdom and Australia to foster technological innovation...more

Troutman Pepper

Texas Federal District Court Rejects All Administrative Procedure Act Challenges to CFPB’s Section 1071 Final Rule

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Monday, the U.S. District Court for the Southern District of Texas granted the Consumer Financial Protection Bureau’s (CFPB or Bureau) motion for summary judgment on all Administrative Procedure Act (APA) challenges brought...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

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

Davis Wright Tremaine LLP

Deadline Approaching for Filing 2024 OFAC Annual Report of Blocked Property

The annual September 30 deadline for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) is fast approaching. Under federal regulations, "all U.S....more

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