The US Department of Commerce (“Department”) issued a final rule (the “Rule”) on December 6, 2024 to amend provisions related to the Department’s review of transactions involving information and communications technology and services (“ICTS”) “designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary that may pose undue or unacceptable risk to the United States or U.S. persons.” The Rule implements important clarifications…
On November 26, 2024, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) imposing new licensing requirements on exports, reexports, and transfers (in-country) to and within Pakistan of certain items identified on the Commerce Control List (“CCL”) that are subject to the Export Administration Regulations (“EAR”). This expansion of controls is intended to address BIS’ concern that certain CCL items that are not currently controlled for Pakistan have…
On December 2, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued long anticipated and extensive new controls to impair China’s indigenous production of advanced semiconductors and other items that can be used in advanced weapon systems, AI, and advanced computing in support of China’s military-civil fusion program. The new rules have a particular focus on the tools used in semiconductor manufacturing and on certain high bandwidth memory (“HBM”), and this…
On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russia’s continued war in Ukraine, and amended US export controls related to Russia and Belarus. Below, we describe the key actions taken by the US Departments of the Treasury, State, and Commerce. 1. OFAC Actions With the aim of disrupting global sanctions evasion networks and domestic suppliers to Russia’s military-industrial base, the US…