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Alexandra Kumar (US)

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On May 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (ā€œBISā€) initiated a rescission of the Biden Administration’s AI Diffusion Rule, which was issued on January 15, 2025 and had been set to take effect on May 15, 2025. The AI Diffusion Rule had introduced additional expansive and complex export controls on certain advanced computing integrated circuits (ā€œICā€) and on model weights for certain advanced closed-weight artificial intelligence (ā€œAIā€) models. Our…

On 11 February 2025, we saw the first public multi-jurisdictional coordinated sanctions action under the Trump Administration when the United States, Australia, and the UK announced joint sanctions against alleged key members of a Russian cybercrime supply chain. This action was taken by the US Department of the Treasury’s Office of Foreign Assets Control (ā€œOFACā€), Australia’s Department of Foreign Affairs and Trade, and the UK Foreign Commonwealth and Development Office (“UK FCDO”).Ā  See the US…

On January 16, 2025, the US Commerce Department’s Bureau of Industry and Security (ā€œBISā€) issued an interim final rule (ā€œIFRā€) related to advanced computing integrated circuits (ā€œICsā€) designed to protect US national security and assist foundries and Outsourced Semiconductor Assembly and Test (ā€œOSATā€) companies in complying with provisions of the US Export Administrations Regulations (ā€œEARā€). The IFR builds on previous waves of semiconductor export controls published in October 2022, October 2023, April 2024, and December…

On October 9, 2024, the US Commerce Department’s Bureau of Industry and Security (ā€œBISā€) issued guidance to financial institutions on best practices for compliance with the US Export Administrations Regulations (ā€œEARā€). The guidance aims to help financial institutions minimize the inadvertent EAR violations, especially under General Prohibition 10 (ā€œGP 10ā€), which prohibits financing or servicing items subject to the EAR with knowledge that a violation of the EAR has occurred, is about to occur, or…