You have always dreamed of going to space. All of us have at some point or another. And the only thing standing between you and that dream were overly-restrictive commodity and technology export licensing requirements on certain space items to specified countries! (well, that, and gravity, and the fact that you are not a billionaire[1], and maybe a few other things).Continue Reading Ticket to Ride – The Commercial Space Activity Exception and Space Tourism: Reduced Export Controls Ease Cross-Border Collaborations (Part IV of IV)
Data, Deals, and Diplomacy, Part II: Big Obligations for Big Data
On October 29, 2024, the Department of Justice (DOJ) published its Proposed Rule outlining prohibitions and restrictions on certain transactions involving bulk U.S. sensitive personal data and U.S. Government-related data. As you may recall from our previous article, this rule stems from recent Executive Order (EO) 14117 on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” The Proposed Rule has potential implications for any business that collects, retains, or deals in data on U.S. persons or certain other data relating to the U.S. Government. Here, we discuss some of the more interesting developments in the Proposed Rule and how it could affect your business.Continue Reading Data, Deals, and Diplomacy, Part II: Big Obligations for Big Data
Commerce Takes on AI: Recent Developments from BIS on AI
In two recent rules, the Department of Commerce, Bureau of Industry and Security (BIS) has begun to take significant steps to monitor, and potentially control access to, U.S. artificial intelligence (AI) technology. AI continues to pose a unique challenge for regulators due to its rapid expansion as a consumer product and potential defense applications.Continue Reading Commerce Takes on AI: Recent Developments from BIS on AI
At Long Last, Final Rule for Outbound Investment Regulations Published
On October 28, 2024, the U.S. Department of Treasury released a pre-publication version of its final rule containing the outbound investment regulations.Continue Reading At Long Last, Final Rule for Outbound Investment Regulations Published
The Benefits of Friends: Removing Space Export Controls for Allies (Part III of IV)
You know who your friends are. You’ve known them for a long time, you understand one another, and, importantly, you trust each other.Continue Reading The Benefits of Friends: Removing Space Export Controls for Allies (Part III of IV)
EU’s New Export Due Diligence Guidelines: Keeping Tabs on Cyber-Surveillance Technology
In 2021, the EU adopted an updated version of the EU Dual-Use Regulation, which establishes common standards for the control of dual-use item exports by EU member states. Among its new provisions, Regulation (EU) 2021/821 introduced, in its Article 5, a “catch-all control” for cyber-surveillance items.Continue Reading EU’s New Export Due Diligence Guidelines: Keeping Tabs on Cyber-Surveillance Technology
The Commercial Industry Gets More Space: Reduced Export Controls Ease Cross-Border Collaborations (Part II of IV)
In a land before time (technologically speaking . . . so, like, the mid-nineties), the most basic software encryption functions were controlled under the U.S. International Traffic in Arms Regulations. The then-current version of Netscape or Lotus Notes (the hot tech of the era) were controlled under the same regulatory regime as missiles and fighter jets. Then, in 1996, an executive order moved encryption to commercial export controls and freed up the software industry to flourish into its current, omnipresent state.Continue Reading The Commercial Industry Gets More Space: Reduced Export Controls Ease Cross-Border Collaborations (Part II of IV)
Space Rules, or . . . Space Rules!: Reduced Export Controls Ease Cross-Border Collaborations (Part I of IV)
We may imagine that a space company begins with only a few screws and some sheet metal in a garage.[1] But regardless of its origins, not long after that early phase, that same company is likely to have a global reach. Commercial space companies inherently involve elements such as international supply chains, foreign customers, and design and engineering talent from around the world.Continue Reading Space Rules, or . . . Space Rules!: Reduced Export Controls Ease Cross-Border Collaborations (Part I of IV)
Banks Do Export, Too: New BIS Guidance Tags Financial Firms with Export Compliance Responsibilities
“Every export—every single one—has a related financial transaction”Continue Reading Banks Do Export, Too: New BIS Guidance Tags Financial Firms with Export Compliance Responsibilities
A (r)AUKUS Discussion in the Space Industry
This week of September 16, Paris will play host to the biggest spectacle of the year (sorry, Olympics), the World Space Business Week. Attendees will come from around the world to discuss advancements in commercial space and global satellite infrastructure. However, it will be the representatives of Australian, UK, and U.S. companies that may have the most to talk about.Continue Reading A (r)AUKUS Discussion in the Space Industry
Export Control Shake-Up: Navigating the Expanded Export Restrictions
On July 29, 2024, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) proposed a series of transformative new rules aimed at tightening controls related to military, intelligence, and security activities under the Export Administration Regulations (EAR). These proposed changes are set to impact how businesses manage exports and interact with end users, expanding the scope of restrictions to cover a broader range of activities and entities. These proposed changes further the U.S. government’s policy goals of using export control regulations to protect human rights around the globe.Continue Reading Export Control Shake-Up: Navigating the Expanded Export Restrictions