Semiconductors Export Controls: A Look Ahead for the Rest of 2024 and Beyond
Brent Carlson and Michael Huneke look at BIS’s October 2022 export controls guidance on advanced computing and semiconductor manufacturing items, the groundwork for compliance enforcement by regulatory bodies, and overall enforcement trends.
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In October 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued landmark export controls guidance on advanced computing and semiconductor manufacturing items that laid the groundwork for compliance enforcement by regulatory bodies. Upon the second anniversary of the BIS’s landmark guidance, Brent Carlson and Michael Huneke look at the bigger picture and identify overall enforcement trends.
Recent enforcement developments, including the reemphasis of the “high probability” standard, show that the US has opted to double-down on export controls by “priming the corporate enforcement engine.”
Companies should understand and adapt to these developments sooner rather than later; those that do will have a competitive advantage over their peers in 2024 and beyond.
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