Author credit: Melissa Mannino, Ragan Updegraff, and Sarah-Jane Lorenzo, Barbara D. Linney
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) appears to be increasing the rate at which it imposes new export controls on various technologies, software and commodities (items). In October alone, BIS published four separate notices that either impose new export controls or propose to do so. We believe BIS is likely to continue to impose export controls on new items, including emerging technologies, at an increased rate. This alert summarizes the export classification changes, final and proposed, that BIS published in October.
To ensure compliance with the U.S. export control laws, companies should verify the export control classification numbers (ECCNs) of the items that they export, including technologies and source code transferred to foreign persons in the United States. Items that may have been eligible for export without a license from BIS may now or soon require an export license.
