On August 6, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a temporary final rule (the “Rule”) that restricts exports of black mass and tungsten waste and scrap without a license. Beginning August 27, 2026, US persons that sell black mass and tungsten waste and scrap must allocate 100 percent of their monthly sales to US persons, unless they first obtain an adjustment or exception from BIS. This Rule implements…
On June 8, 2026, the US Department of Defense (“DoD”) published an update to its list of “Chinese military companies” (“CMCs”) operating directly or indirectly in the United States (the “1260H List”), pursuant to Section 1260H of the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA 2021”). The updated list is available here. The DoD press release states that this update is part of the US government’s continuing effort to highlight and counter…
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 February 24, 2022, the Bureau of Industry and Security (“BIS”) within the US Commerce Department (“Commerce”) issued a final rule (“Final Rule”) effective immediately that implements a sweeping series of new export control measures under the Export Administration Regulations (“EAR”) against Russia. Commerce’s press release regarding these new controls can be found here. These new US export control measures primarily target Russia’s defense, aerospace, and maritime sectors and are intended to curtail Russia’s ability…