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US Export Controls

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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…

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…