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AES Update for New BIS License Types

The Automated Export System has been modified to report shipments governed by last Fall's Certain Advanced Computing and Semiconductor Manufacturing Items; Supercomputer and Semiconductor End Use Rules.

BIS: Chips Rules Add Macau

This rule adds the destination of Macau to the scope of the Regional Stability (RS) controls that were implemented specific to China in the October 7 advanced computing and semiconductor manufacturing equipment rule. …

BIS: Section 1758 Bio & Toxins Rule Set

The Bureau of Industry and Security (BIS) published the final rule to amend the Export Administration Regulations (EAR) to reflect decisions made at Australia Group (AG) Virtual Implementation …

DDTC: Voluntary Disclosure – Violations of the Arms Export Control Act

ITAR §127.12 describes the information which should accompany a voluntary disclosure. Historically, respondents to this information collection submitted their disclosures to DDTC in writing via …

State/DDTC: Seeks Comments on Open GL Recordkeeping

DDTC has launched a pilot program pursuant to its authorities in ITAR § 120.22(b) in order to assess the concept of an Open General License (OGL) mechanism by which it may authorize …

Japan-U.S. Commercial and Industrial Partnership

Comments sought regarding areas and priorities for U.S. and Japan export control cooperation to help inform the work of the Japan-U.S. Commercial and Industrial Partnership (JUCIP) Export Control …

Team Telecom Nixes Cuba Link

The Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector, aka “Team Telecom” has recommended that the Federal Communications …

Industry Response to Semiconductor Controls

The year’s final meeting of the BIS Regulations and Procedures Technical Advisory Committee (RAPTAC) afforded participants a high-level overview of what industry comments on October’s …

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January 2025 Export Practitioner

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Re-Designation Stymies Potential Sanctions Revanchists

In a move some read as an effort to "Trump Proof" the Treasury's Russian sanctions regime, OFAC is re-designating pursuant to Executive Order (E.O.) 13662 almost 100 entities already designated pursuant to E.O. 14024. This codification provides legislative backing, making it more difficult for any administration to unilaterally lift these sanctions. This move places the sanctions under rules governed by the Countering America’s Adversaries Through Sanctions Act (CAATSA). CAATSA, enacted in 2017, codified and expanded existing sanctions imposed by executive orders, including E.O. 13662. As a result of these entities’ designation pursuant to E.O. 13662, foreign persons, including foreign financial institutions, that knowingly facilitate significant transactions for or on behalf of any of these entities could be subject to mandatory secondary sanctions under the Ukraine-/Russia-related sanctions program.

Entity List Updates

BIS added 11 Chinese entities to the Entity List, 10 for advanced artificial intelligence research and one for development of lithography technology for advanced-node fabrication facilities. The committee also removed three Indian nuclear research entities after diplomatic considerations. …

Estevez Exit Interview

Alan Estevez, Undersecretary of Commerce for Industry and Security, delivered remarks Tuesday at Washington's CSIS Wadhwani AI Center, focusing on the evolving role of export controls in safeguarding U.S. national security and addressing technological threats. The conversation, moderated by Greg Allen, Director of CSIS's Wadhwani AI Center, covered key achievements, challenges, and future priorities for the Bureau of Industry and Security (BIS).

Biotech as Domain for Great Power Competition

The Center for a New American Security (CNAS) released a new report, Biopower: Securing American Leadership in Biotechnology by Vivek Chilukuri and Hannah Kelley . The report identifies key …

Due Diligence Measures Rule Released

The Bureau of Industry and Security (BIS) is revising the Export Administration Regulations (EAR) to provide additional due diligence procedures for advanced computing integrated circuits (ICs). This interim final rule (IFR) aims to safeguard U.S. national security and support foundries and Outsourced Semiconductor Assembly and Test (OSAT) companies in complying with EAR provisions related to advanced computing ICs in the supply chain. Additionally, the IFR updates and clarifies changes introduced in BIS’s December 2, 2024, IFR, titled “Foreign-Produced Direct Product Rule Additions, and Refinements to Controls for Advanced Computing and Semiconductor Manufacturing Items” (FDP IFR). It also extends the deadline for written comments on the FDP IFR to March 14, 2025.

Bio-Lab Equipment Dual Use Controls Released

BIS has published an Interim Final Rule revising the Export Administration Regulations (EAR) to address national security and foreign policy concerns related to dual-use biotechnology tools. It imposes new export controls on specific laboratory equipment and related technology to prevent misuse, particularly by foreign adversaries.

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