- 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
BIS Rescinds Biden Administration’s AI Diffusion Export Control Rule
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…
Client Alert: New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions
In new guidance published on October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued recommendations about its expectations for financial institutions in complying with U.S. export control obligations.
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BIS Issues “Best Practices” Guidance for Mitigating Export Diversion Risk
On July 10, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released guidance to provide helpful “best practices” for companies and universities who have received a “supplier list” letters, Project Guardian requests, “red flag” letters, or “is informed” letters from BIS.
These notifications generally require the recipients of the letter to take…
BIS Updates Rules on Advanced Semiconductors
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…
BIS and DDTC Amendments Add Nicaragua to EAR Country Group D and ITAR § 126.1
On March 15, 2024, the Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) amended the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) to implement new restrictions on trade with Nicaragua.
BIS’s amendments moved Nicaragua from Country Group B to Country Group D, applying a…
Commerce, Treasury, DOJ Publish Tri-Seal Sanctions and Export Control Compliance Note
On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and…
BIS Amends Licensing Requirements of Certain Cameras and Camera Systems
The U.S. Department of Commerce, Bureau of Industry and Security (BIS), published a final rule on February 23, 2024, amending the Export Administration Regulations (EAR) by revising license requirements for certain cameras, systems, and related components to eliminate license requirements for certain cameras to Country Group A:1. In addition to these changes, BIS is adding…
BIS/OFAC Announce New Sanctions and Entity List Designations on Two-Year Anniversary of Russia’s Invasion of Ukraine
Feb. 23, 2024–Today, following the death of opposition politician and anti-corruption activist Aleksey Navalny, and after two years of Russia’s unprovoked and unlawful full-scale invasion of Ukraine, the Commerce Department’s Bureau of Industry and Security (BIS) imposed additional export restrictions on 93 entities under 95 entries in Russia and seven other destinations. Sixty-three of the…
New Section 232 Exclusion Proposed Rules Will Force Additional Burden of Proof on Importers and Domestic Producers
On August 28, 2023, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) proposed new rules to streamline and strengthen the Section 232 Exclusions Process for Steel and Aluminum imports. The proposed rules will build on the five existing interim final rules and respond to public comments received by BIS since February 2022. BIS…