The main US export controls regulator continues to take steps to demonstrate its focus on enforcement. Specifically, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Rule”) on September 16, 2024, effective immediately, to amend the provisions in its regulations focused on the voluntary self-disclosure (“VSD”) process. Many of the changes in the Rule reflect guidance previously issued by BIS in individual memoranda (available here), which are now…
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (the “IFR”) on September 6, 2024 that imposes new “plurilateral” worldwide licensing controls on certain advanced technologies, including certain quantum, semiconductor-related and additive manufacturing items, under new and amended ECCNs in the Export Administration Regulations (the “EAR”), introduces a new license exception for certain items to allied countries implementing equivalent controls, adds two new general licenses for certain Gate…