On May 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) 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 (“IC”) and on model weights for certain advanced closed-weight artificial intelligence (“AI”) models. Our…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended Venezuela General License (“GL”) 41 to wind-down, rather than authorize, certain transactions related to the operation and management of Chevron Corporation’s joint venture with Petróleos de Venezuela, S.A. (“PdVSA”) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (“PdVSA Related Entities”). OFAC issued the original GL 41 on November 26, 2022, which authorized certain transactions…
On February 4, 2025, the White House issued a National Security Presidential Memorandum (“NSP Memo”) outlining President Trump’s intention to impose maximum economic and political pressure on the government of the Islamic Republic of Iran (“Iran”), including by enhancing enforcement efforts and modifying or rescinding any existing general license or guidance that provides Iran with “any degree of economic or financial relief.” In addition, on February 6, 2025, the US Treasury Department’s Office of Foreign…
On November 26, 2024, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) imposing new licensing requirements on exports, reexports, and transfers (in-country) to and within Pakistan of certain items identified on the Commerce Control List (“CCL”) that are subject to the Export Administration Regulations (“EAR”). This expansion of controls is intended to address BIS’ concern that certain CCL items that are not currently controlled for Pakistan have…