In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria
Years ago, when I was a baby lawyer living in a group house in DC, we had a toaster—my toaster. I had owned the toaster
Continue Reading Throwing Away the Toaster: Where AI Controls Are Now and May be Heading
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I
On December 2, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) issued a new set of regulations targeting semiconductors manufacturing equipment (SME) and high-bandwidth memory (HBM) chips. The updates are a part of BIS’s ongoing efforts to target semiconductors in attempt to slow down China’s advancement of AI. In the race to artificial general intelligence, advanced-node semiconductors play an outsized role in a country or company’s ability to progress.Continue Reading The Persistence of (High Bandwidth) Memory: Semiconductor Manufacturing Equipment and Korean Semiconductor Manufactures Face Harsher Restrictions Under New HBM Rules
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)
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
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)
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
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)