On May 31, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance clarifying that a license continues to be required under the Export Administration Regulations (“EAR”) for exports of advanced computing items to entities located in any country, if those entities are headquartered in Country Group D:5 (including China) or Macau, or have “an ultimate parent company” headquartered in Country Group D:5 or Macau. The BIS Guidance was prompted by…
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule, effective January 15, 2026, revising the license review policy for exports from the United States of certain commercially available advanced computing semiconductors to end users in China and Macau—moving from a presumption of denial to case‑by‑case review under certain conditions. The case-by-case review policy is only available for exports meeting strict requirements, including various certifications as to sufficient supply…
On October 21, 2025, the US Department of Commerce’s International Trade Administration (“ITA”) announced the implementation of the July 23, 2025 Executive Order (“EO”) Promoting the Export of the American AI Technology Stack (the “American AI Exports Program”). Following our earlier post addressing the White House’s AI Action Plan and the EO, this update focuses on the implementation of the EO and the ITA’s request for public feedback. As a reminder, the EO directs the Secretary…
On August 26, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule removing the Syrian Sanctions Regulations (31 CFR Part 542) from the Code of Federal Regulations (“OFAC Final Rule”). This action follows the issuance of Executive Order (“EO”) 14312 on June 30, 2025, which terminated the national emergency declared in EO 13338 and revoked multiple Syria-related sanctions authorities. Our blog post on the issuance of EO…