On October 28, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a first round of FAQs regarding the advanced computing and semiconductor manufacturing Interim Final Rule, published on October 13, 2022 (87 Fed. Reg. 62,186) (the “Rule”) and amending the Export Administration Regulations (“EAR”). The FAQs are available here and the Rule is available here. Our blog post related to the Rule is located here. The FAQs address certain questions around:…
On October 7, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued the much anticipated rules aimed at restricting China’s ability to obtain advanced computing chips, develop and maintain supercomputers, and manufacture advanced semiconductors (“Rule”) (87 FR 62186). In addition to formalizing the licensing requirements included in the recent BIS “is informed” letters issued to certain US companies on related matters, the Rule imposes a wide range of new and enhanced restrictions…
On October 6, 2022, the Assistant Secretary for Export Enforcement issued a policy aimed at enhancing enforcement of the antiboycott rules administered by the US Department of Commerce (“Commerce”). The following day a final rule came into effect updating Commerce’s guidance on charging and penalty determinations related to violations of the antiboycott provisions of the Export Administration Regulations (the “EAR”). The changes are intended to bring penalty determinations in line with Commerce’s current view of…
On October 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of State, issued the Russia-related Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex (“the Alert”). OFAC also published one new Russia-related frequently asked question (“FAQ”). The Alert outlines impacts of the coordinated sanctions and export controls that have led to shortages of supplies…