UPDATE: [Close of Comments on Commerce Cyber Rule]
Client Alert | 1 min read | 01.20.22
On January 12, 2022 the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a federal register notice delaying the effective date of new controls on cybersecurity items and an accompanying new license exception. The rules are now set to take effect on March 7, 2022.
The new controls were published in an interim final rule on October 21, 2021, please see our earlier client alert on this. Broadly speaking, they cover (a) items, including software, for the generation, command and control, or delivery of intrusion software and (b) internet protocol (IP) network communication surveillance equipment. BIS delayed the implementation to give industry additional time to comply with the new restrictions as well as update internal compliance procedures, and to provide BIS itself time to provide additional guidance on the rule. BIS may also consider some modifications to the rule, but is not reopening the comment period and these modifications based on the latest comments will most likely be made, if at all, sometime after the new effective date for the interim final rule.
Insights
Client Alert | 8 min read | 11.12.24
The Month in International Trade – October 2024
This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Jana del-Cerro, Anand Sithian, or Simeon Yerokun or any member of the International Trade Group.
Client Alert | 3 min read | 11.11.24
Allegations of a Litany of Lyin’: Penn State Settles Claims of Cybersecurity Noncompliance
Client Alert | 1 min read | 11.08.24
A Common-Sense Change to the Continuous SAM Registration Requirement at FAR 52.204 7
Client Alert | 7 min read | 11.08.24
New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions