The Department of Commerce’s (“DOC”) Bureau of Industry and Security (“BIS”) has published an interim final rule, as well as a request for comments, regarding new export controls for advanced computer, supercomputer, semiconductor, and manufacturing items. This update to the interim final rule serves to correct inadvertent errors and clarify export licensing procedures outlined in interim final rules “Export Controls on Semiconductor Manufacturing Items” (SME IFR) (88 FR 73424, October 25, 2023) and “Implementation of Additional Export Controls: Certain Advanced Computing Items; Supercomputer and Semiconductor End Use; Updates and Corrections” (AC/S IFR) (88 FR 73458, October 25, 2023). Corrections include revisions to license exceptions under the Export Administration Regulations (“EAR”) for products such as EUV masks, clarifications regarding semiconductor and semiconductor manufacturing item classification under the EAR, and further clarifications regarding end-user controls as they pertain to certain U.S. persons or Country Groups.

Read the notice on the Federal Register website here.

Crowell & Moring, LLP continues to monitor developments in export control policy and their potential effect on customers and businesses going forward.

Tags: BIS, Department of Commerce, EAR, export, Export controls, Semiconductors
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Photo of Jana del-Cerro Jana del-Cerro

Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana

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Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana works with clients across a broad range of industries, from traditional aerospace and defense manufacturers and multi-national software companies, to start-ups in the technology sector, and she regularly represents them before the Departments of State, Commerce, and Treasury in responding to government inquiries, conducting internal reviews, and in compliance investigations and voluntary disclosures.

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Photo of Chandler Leonard Chandler Leonard

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce…

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.

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Andrew J. Schlegel

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

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Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.

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