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…
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“IFR”) on January 15, 2025, that introduces new export controls on artificial intelligence (“AI”) model weights and advanced computing integrated circuits (“IC”) in the Export Administration Regulations (“EAR”). The new controls are intended to simultaneously restrict exports to certain countries while establishing a framework to support the diffusion and supply of certain AI model weights and advanced computing ICs…
On January 16, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) related to advanced computing integrated circuits (“ICs”) designed to protect US national security and assist foundries and Outsourced Semiconductor Assembly and Test (“OSAT”) companies in complying with provisions of the US Export Administrations Regulations (“EAR”). The IFR builds on previous waves of semiconductor export controls published in October 2022, October 2023, April 2024, and December…
On January 16, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule (the “IFR”) revising the Export Administration Regulations (“EAR”) to impose new controls on certain biotechnology equipment and related technology. As stated in the IFR, the new controls are necessary to protect against US national security and foreign policy interests “given the dual-use nature and relevance of specific biotechnology equipment to contribute to the research and development…