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Know Your Customers U.S. Commerce Department

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

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

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The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Cozen O'Connor

U.S. Department of Commerce Proposes a New KYC Rule Applicable to U.S. IaaS Providers

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On January 29, 2024, the U.S. Department of Commerce’s (Department) Bureau of Industry and Security issued a notice of proposed rulemaking (Proposed Rule) that proposes a new Customer Identification Program (CIP) and other...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

Skadden, Arps, Slate, Meagher & Flom LLP

Know Your Cloud Customer: Commerce Department Proposes To Regulate Foreign Access to US IaaS Products

On January 29, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) released a proposed rule (Proposed Rule) that would require U.S. cloud services providers (a.k.a. Infrastructure as a Service, or IaaS,...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - February 14, 2024

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Teradyne, a Massachusetts-based supplier of semiconductor testing equipment, has reportedly pulled $1 billion of manufacturing equipment out of China in 2023 following export controls on advanced computing materials and...more

Morrison & Foerster LLP

BIS Proposes Rule to Address Challenges of Artificial Intelligence and Malicious Cyber-Enabled Activities

On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a proposed rule to prevent foreign actors from using U.S. cloud computing services for malicious cyber activities. The proposal...more

Fenwick & West LLP

Commerce Department Proposes Sweeping Know Your Customer & Other Requirements for IaaS Providers

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The United States Department of Commerce (Commerce) issued a notice of proposed rulemaking (NPRM) seeking comments on new proposed regulations that would, if enacted, impose extensive Know Your Customer (KYC) and Customer...more

Akin Gump Strauss Hauer & Feld LLP

Akin Intelligence - November 2023

Welcome to the November edition of Akin Intelligence. Looking back, October 2023 may be remembered as the month when the U.S. government tried to assume the mantle of global leadership on responsible artificial intelligence...more

Paul Hastings LLP

New Emphasis on Human Rights and Human Rights Due Diligence in U.S. Export Controls

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As the European Union has made continued progress toward implementing a holistic human rights legislative agenda, the United States, in the wake of the recent second Summit for Democracy, began to push its own set of human...more

Guidepost Solutions LLC

Sanctions and The Supply Chain: Basic Steps to Protect Yourself

With the Russian-Ukraine war’s ever-expanding sanctions landscape, the supply chain is even more complex than it already was, and enforcement risk is even higher given the broader array of U.S. federal and international...more

Bracewell LLP

KYC in a Digital World, How New Sanctions and AML Expectations Have Upped the Stakes and What you Need to Do About it

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“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent...more

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