On January 2, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM) soliciting public input on securing the supply chain for unmanned aircraft systems (UAS). BIS seeks to address supply chain risks posed by the involvement of foreign adversaries in UAS-related information and communication technology and services (ICTS).   

The ANPRM outlines potential threats from foreign adversaries, especially China and Russia, whose involvement in UAS ICTS supply chains could enable remote access and manipulation of these devices, potentially compromising sensitive data.   

BIS invites public commentary on topics such as:   

  • Defining UAS and their critical components.   
  • Assessing risks tied to ICTS transactions involving foreign entities.   
  • Evaluating the economic impact of proposed regulations.   
  • Exploring measures to mitigate identified risks.   
  • Developing processes to request exemptions for restricted transactions.   

This ANPRM is part of broader efforts under the Biden-Harris Administration to safeguard critical technology and infrastructure, authorized by Executive Order 13873, “Securing the Information and Communications Technology and Services Supply Chain.” The executive order empowers the Commerce Department to oversee and restrict ICTS transactions that pose unacceptable risks to U.S. national security, critical infrastructure, or the economy.   

Public comments on the ANPRM must be submitted by March 4, 2025, and the full text is available on the Federal Register website.  

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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

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.

Photo of Dmitry Bergoltsev Dmitry Bergoltsev

Dmitry Bergoltsev is a senior international trade analyst 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

Dmitry Bergoltsev is a senior international trade analyst 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. He 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).