On May 13, 2025, the Department of Commerce announced that it was rescinding a January 15, 2025 Interim Final Rule that revised the controls under the Export Administration Regulations (EAR) on advanced computing integrated circuits (ICs) and added a new control on artificial intelligence (AI) model weights for certain advanced closed-weight dual-use AI models. See
Thompson Hine LLP Blogs
Latest from Thompson Hine LLP
President Trump Issues America First Investment Policy Memorandum Impacting Foreign Direct Investment into the United States and Outbound Investment to Foreign Adversaries such as China.
From our SmartTrade Group at Thompson Hine!
President Trump issued the America First Investment Policy Memorandum on February 21, 2025 https://www.whitehouse.gov/presidential-actions/2025/02/america-first-investment-policy/ proclaiming that the United States “is committed to maintaining the strong, open investment environment that benefits our economy and our people, while enhancing our ability to protect the United States from new and evolving
SEC New Cyber and Emerging Technologies Unit
The administration announced Thursday that it replaced the unit responsible for many of the SEC’s crypto registration suits with a new fraud-focused unit that will take a broader review of “cyber and emerging technologies.”
The Cyber and Emerging Technologies Unit will prioritize fraud cases that leverage novel tech including crypto, artificial intelligence, machine learning and
N40 Digital Asset Summit Review
Last week I took time to attend the N40 Digital Asset Summit which brought together industry leaders, innovators, and family offices to discuss the future of blockchain, digital assets, Web3, crypto and the role for AI in the space. The event was robust with fabulous panels and a wealth of information and insight. As US
New Export Controls on Advanced Computing ICs and Certain Closed AI Model Weights
UPDATE: On May 13, 2025, the Department of Commerce rescinded this Interim Final Rule. See Thompson Hine update of May 14, 2025. BIS plans to publish a Federal Register notice formalizing the rescission and will issue a replacement rule in the future.
On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry
BIS Adds 27 Chinese Companies to Entity List
On January 15, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued two Final Rules adding 27 companies to the Entity List.
In the first Final Rule, BIS added 16 entities under the destinations of China (14) and Singapore (2). These entities are being added to the Entity List due to
BIS Seeks to Further Strengthen Export Controls Targeting China’s Advanced Semiconductor Industry
On December 2, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued two new rulemakings in an ongoing effort to “further impair [China’s] capability to produce advanced-node semiconductors that can be used in the next generation of advanced weapon systems and in artificial intelligence (AI) and advanced computing, which have significant military
Most Recent ABA Opinion Provides Comprehensive Ethics Guidance on Generative AI Use
The ABA Standing Committee on Ethics and Professional Responsibility (the “Committee”) recently issued its first opinion on generative AI and not a day too soon. While states such as Florida, California, West Virginia, and Kentucky, as well as the District of Columbia have issued generative AI guidance, most states have yet
Final Rule Issued on Outbound U.S. Investments in National Security-Related Technologies in Countries of Concern
The Department of the Treasury has issued a Final Rule to implement Executive Order 14105 of August 9, 2023, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern.” This Final Rule provides the operative regulations and a detailed explanatory discussion regarding the intent and application of these new U.S.
U.S. Treasury Department Issues Proposed Rule Limiting Outbound Investments in “Countries of Concern”
On June 21, 2024, the Department of the Treasury issued a Notice of Proposed Rulemaking (NPRM), “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern.” The NPRM builds on the Advance Notice of Proposed Rulemaking (ANPRM) issued in August 2023 in response to President Joseph Biden’s Executive Order 14105