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BIS

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On June 30, 2025, the White House reissued National Security Presidential Memorandum-5 (ā€œ2025 NSPM-5ā€) focused on Cuba policy that it published in largely the same form in the first Trump Administration (see the ā€œ2017 NSPM-5ā€). As acknowledged in Section 4(a) of the reissued document, much of the contents of the 2025 NSPM-5 was already implemented in the first Trump Administration pursuant to the 2017 NSPM-5. Along with 2025 NSPM-5, the White House issued a related…

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…

In less than two weeks, we have seen Syria go from one of the most heavily sanctioned countries on the planet to a country well on the road to establishing normal trade relations with the Western world. The latest flurry of developments started on May 13, 2025, when President Trump caught much of the world by surprise when he said in a speech in Riyadh: ā€œI will be ordering the cessation of sanctions against Syria…

In an era of intensifying geopolitical tensions, companies with operations in the U.S. must navigate an increasingly fragmented and national security-driven regulatory landscape governing cross-border transfers of many different types of data, including personal data and technical information used in R&D and patent filings. The U.S. Department of Justice’s new Data Security Program (DSP) essentially prohibits U.S. persons from making certain volumes of Americans’ personal data available to entities headquartered or residing in China (including…