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…
On January 16, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule entitled “Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles” (“Final Rule”) prohibiting certain transactions involving the sale or import of connected vehicles integrating specific hardware and software, or those components sold separately, with a sufficient nexus to China or Russia. The Final Rule, which follows the earlier notice of proposed rulemaking (“NPRM”)…
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…