On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced controls on advanced computing integrated circuits (ICs) and certain closed artificial intelligence (AI) model weights. “To strengthen U.S. security and economic strength,” the Biden-Harris administration released an Interim Final Rule (IFR) titled “Framework for Artificial Intelligence Diffusion.” The rule
Information Technology/Cybersecurity
Department of Commerce Proposes Ban on Connected Vehicles Using Chinese or Russian Hardware and Software
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OFAC Issues Revised Russia Telecommunications General Licenses and an Alert on Russian Attempts to Evade Sanctions
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On September 4, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia General License (GL) 25E that continues to authorize all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. This continues to allow for services incident to the exchange of…
BIS Expected to Propose Barring Chinese Software in Autonomous and Connected Vehicles
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On March 1, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Advanced Notice of Proposed Rulemaking (ANPRM) to explore national security risks posed by connected vehicles (CVs) that incorporate Information and Communications Technology and Services (ICTS) from “foreign adversaries,” including China and the Hong Kong Special Administrative Region. The initiative…
Commerce and State Departments Issue Proposed Rules Addressing Restrictions on U.S. Persons’ Support for Foreign Military, Intelligence, and Security Services and Controls to Protect National Security and Human Rights
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On July 29, 2024, both the Departments of Commerce and State issued separate but complementary proposed rules seeking public comment on enhanced restrictions on exports, reexports, or support to military or intelligence end users and end uses in countries of concern, consistent with the Fiscal Year 2023 National Defense Authorization Act (NDAA). The Department of Commerce’s…
Regulations Issued to Redesignate BIS as the Authority Administering Rules for Information and Communications Technology and Services Tied to Foreign Adversaries
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The Department of Commerce’s Bureau of Industry and Security (BIS) has issued a Final Rule that redesignates regulations governing the procedures for the review of certain 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…
BIS and OFAC Impose New Prohibitions Against Kaspersky’s Entities and Operations
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BIS Prohibition on Kaspersky Products
On June 20, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Determination that bans a range of transactions involving Kaspersky Lab, Inc. and its related entities’ (Kaspersky) cybersecurity and anti-virus products and services. The Final Determination prohibits Kaspersky from engaging in certain Information…
U.S. Aid Package for Ukraine, Israel and the Indo-Pacific Incorporates Extensive Sanctions and Export Control Reforms
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On April 24, 2024, President Biden signed into law a broad national security package which included the Israel Security Supplemental Appropriations Act, 2024; Ukraine Security Supplemental Appropriations Act, 2024; Indo-Pacific Security Supplemental Appropriations Act, 2024; 21st Century Peace through Strength Act; FEND off Fentanyl Act; and the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act.
White House Releases Updated Critical and Emerging Technologies List
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The Executive Office of the President, via the National Science and Technology Council, has released an updated list of critical and emerging technologies that are potentially significant to U.S. national security. This list updates and revises the critical technologies list identified in the October 2020 report, “National Strategy for Critical and Emerging Technologies” and an…
OFAC Issues Updated Iran General License Covering Certain Services, Software and Hardware for Communications
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On September 23, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Iran General License (GL) D-2 which authorizes the export, reexport by U.S. persons to Iran of certain services, software and hardware incident to communication. The purpose of the revised GL is to bring this OFAC guidance on…