Information Technology/Cybersecurity

On June 9, 2021, President Joseph Biden issued an Executive Order (E.O.) to further address the threat posed to the U.S. information and communications technology and services (ICTS) supply chain declared in Executive Order 13873 (the “Telecom Supply Chain E.O.”; see Update of May 16, 2019).  The June 9, 2021 E.O. also revoked and

The U.S. Department of Commerce’s Bureau of Industry & Security (BIS) issued a final rule amending the Export Administration Regulations to eliminate most reporting requirements related to open source encryption software and certain “mass market” encryption items and to revise the Commerce Control List.

Key Notes:

  • BIS issued a final rule eliminating certain reporting requirements

On January 5, 2021, President Donald Trump issued an executive order declaring that beginning on February 19, 2021, “any transaction by any person, or with respect to any property, subject to the jurisdiction of the United States, with persons that develop or control the following Chinese connected software applications, or with their subsidiaries, … :

On October 15, 2020, the White House released a report, “National Strategy for Critical and Emerging Technologies,” outlining steps the United States will take to preserve its competitive edge in certain critical and emerging technologies. Noting in a statement the importance of U.S. dominance in the science and technology sectors, the White House

Effective October 15, 2020, the Department of the Treasury’s September 15 final rule (“Rule”) will modify certain regulations of the Committee on Foreign Investment in the United States (CFIUS) pursuant to the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). In a previous blog post, we noted that the Rule would change the

On October 1, 2020, the Department of the Treasury issued two related advisories to assist U.S. companies in efforts to combat ransomware scams and attacks. In addition to offering guidance, the advisories note that anti-money laundering and economic sanctions regulations implemented and enforced by Treasury’s Office of Terrorism and Financial Intelligence may be triggered by

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued an Interim Final Rule amending General Prohibition Three, also known as the foreign-produced direct product reexport rule, so that this General Prohibition applies to certain additional foreign-made items destined for certain persons designated with a new footnote on BIS’ Entity List. Specifically, this

On March 12, 2020, President Donald Trump signed into law H.R. 4998, the “Secure and Trusted Communications Networks  Act of 2019,” which prohibits the use of certain federal funds and subsidies to purchase communications equipment or services posing national security risks. The Act, passed by both the House of Representatives and the Senate by

On December 30, 2019, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued an interim final rule seeking to amend the International Traffic in Arms Regulations (ITAR) with definitions more clearly explaining activities that are not considered to be exports, reexports, retransfers or temporary imports of secured and unclassified technical data. This 

On November 27, 2019, the Department of Commerce published in the Federal Register proposed regulations for its review and potential blocking of transactions involving the information and communications technology and services supply chain (ICTS Supply Chain). The notice follows President Donald Trump’s Executive Order of May 15, 2019, “Securing the Information and Communications Technology