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US Export Controls

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On July 23, the White House unveiled its much-anticipated AI Action Plan, followed the same day by an Executive Order on “Promoting The Export of the American AI Technology Stack.” Following our earlier post considering the Action Plan from a multi-practice standpoint (US AI Vision in Action: What Businesses Need to Know About the White House AI Action Plan – Connect On Tech), this update focuses on the key export control provisions in the Action…

On January 14, 2025, President Biden took action towards rescinding Cuba’s designation as a State Sponsor of Terrorism (“SST”) and to remove restrictions on financial transactions with certain Cuban parties by issuing to Congress a Certification of Rescission of Cuba’s Designation as a State Sponsor of Terrorism (“Certification”) and National Security Memorandum 29 (“NSM-29”) revoking a past National Security Presidential Memorandum related to Cuba that had been issued by then-President Trump in June 2017. President…

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…

The US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (the “IFR”) on September 6, 2024 that imposes new “plurilateral” worldwide licensing controls on certain advanced technologies, including certain quantum, semiconductor-related and additive manufacturing items, under new and amended ECCNs in the Export Administration Regulations (the “EAR”), introduces a new license exception for certain items to allied countries implementing equivalent controls, adds two new general licenses for certain Gate…