Zachary Rozen

Nov 8, 2024 | jdsupra.com | Zachary Rozen |Marcus Burden |Nancy Fischer |Samantha Franks

Takeaways The Final Rule formalizes a new governmental system to monitor through a notification process and, when necessary, restrict investments in China that may be viewed as a national security risk. The regulations have broad applicability to investments, greenfield projects, joint ventures and other arrangements in the semiconductor, artificial intelligence and quantum computing sectors.

Sep 11, 2024 | globaltradeandsanctionslaw.com | Nancy Fischer |Stephan Becker |Zachary Rozen |Barbra Kim

On September 5, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule imposing significant new export controls on quantum computing, cryocooling systems, semiconductor equipment, and additive manufacturing technologies. These controls are meant to align U.S. regulations with recent regulations adopted by several close U.S. allies and are intended to address national security concerns related to the proliferation of sensitive technologies.

Mar 25, 2024 | globaltradeandsanctionslaw.com | Stephan Becker |Aaron Hutman |Benjamin Cote |Zachary Rozen

The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the military end use and military end user restrictions.

Feb 6, 2024 | globaltradeandsanctionslaw.com | Stephan Becker |Benjamin Cote |Zachary Rozen |Arielle Heffez

Takeaways:On January 16, 2024, the Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) announced several updates to its Voluntary Self-Disclosure (VSD) process aimed at enhancing the program’s overall efficiency and effectiveness. These enhancements create a more streamlined disclosure process for minor violations, including through abbreviated narratives, quarterly bundled disclosures, and limiting the requirement to include a five-year lookback.

Nov 13, 2023 | globaltradeandsanctionslaw.com | Marques Peterson |Benjamin Cote |Zachary Rozen |Erin Kwiatkowski

On October 5, 2023, the National Archives Information Security Oversight Office (ISOO) released a joint notice to provide guidance on facility clearances for joint ventures (JVs) in the National Industrial Security Program (NISP). This guidance addresses the interaction of NISP requirements and an October 16, 2020 Small Business Administration (SBA) rule on JVs and also aims to clarify confusion arising from a Government Accountability Office (GAO) decision interpreting the SBA 2020 rule.