- Key takeaway #1The new guidance amounts to prohibitions on U.S. and non-U.S. persons using, selling, transferring, financing, or servicing Huawei’s Ascend 910B, 910C, and 910D chips, as well as other comparable chips from other Chinese companies.
- Key takeaway #2While the U.S. Department of Commerce Bureau of Industry and Security (BIS) has issued some advanced computing-related
Bureau of Industry and Security (BIS)
BIS Rescinds Biden Administration’s AI Diffusion Export Control Rule
By Jeffrey L. Snyder, Jeremy Iloulian & Edward Goetz on
The Bureau of Industry and Security (BIS) announced plans on May 13,2025, to rescind the Biden Administration’s AI diffusion export control rule, which was set to take effect on May 15. BIS will issue a formal rescission notice in the Federal Register and plans to introduce a replacement rule in the future. BIS enforcement officials…
BIS Adds and Removes Persons from the Unverified List
By Crowell & Moring on
Posted in Bureau of Industry and Security (BIS)
On April 25, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule that added 18 new persons and removed five persons from the Unverified List (UVL).
Of the 18 persons added in the UVL, five are located in China, six are located in Finland, three are located in…
The Trump Administration Targets China, Iran, and Pakistan in its First Export Regulatory Action
On March 25, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released two final rules that announced the addition of 80 new entities to the Entity List (see BIS press release here). In its press release, BIS officials stated that the Entity List is only one of the powerful…
Commerce Releases ANPRM to Bolster Drone Supply Chain Security
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…
BIS Amends Voluntary Self-Disclosure Process and Penalty Guidelines and Adds First-Ever Chief of Corporate Enforcement
On September 12, 2024, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a final rule to amend the Export Administration Regulations (EAR) revising provisions related to the voluntary self-disclosure (VSD) process for persons who believe that they may have violated the EAR, or any order, license or authorization issued thereunder. The…
OFAC, State Department, and BIS Expand Russian/Belarusian Sanctions
On August 23rd, 2024, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State (State), and the Commerce Department’s Bureau of Industry and Security (BIS) acted against Russia’s international supply chains.
OFAC and State collectively sanctioned nearly 400 individuals and entities. Of note, this included a substantial focus on…
ITAR and EAR Proposed Rules Expand Controls on U.S. Person Services
On July 25, 2024, the U.S. Departments of State and Commerce issued new proposed rules that, if implemented, would (1) increase the restrictions associated with U.S. persons providing services in support of non-U.S. military-related end users / uses; and (2) implement new controls associated with exports, reexports, and transfers of items subject to the EAR…
Growing Technology Supply Chain Risks: Kaspersky Lab Software Banned in First Use of ICTS Supply Chain Prohibition
On June 20, 2024, the U.S. Department of Commerce Bureau of Industry and Security announced its first Final Determination pursuant to the Securing the Information and Communications Technology and Services Supply Chain (ICTS) regulations, prohibiting Kaspersky Lab, Inc. from providing anti-virus software and cybersecurity products or services in the United States or to U.S. persons…
BIS Streamlines Export Controls for Transfers to and Among Australia and the UK
By Dmitry Bergoltsev & Chandler Leonard on
On April 19, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to enhance technological innovation and support the goals of the AUKUS trilateral security partnership.
The interim final rule makes six primary export control policy changes that effectively provide Australia and the UK nearly the same…