Law Firm Expecting 'Total Chaos' From New BIS Export Controls
The Bureau of Industry and Security's new sweeping set of export controls (see 2210070049) will “likely damage” the Chinese semiconductor and advanced computing industries and the U.S. and foreign companies that sell to those sectors, ArentFox said in an Oct. 10 alert. “While that was clearly the point of the new rule, we are expecting total chaos for a while,” the law firm said, adding that there is a “lot to unpack” in the 139-page rule.
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The firm said a host of businesses that operate in these industries will need to determine if their transactions now require a license. “The key takeaway: Virtually any company that uses computers, servers, and [integrated circuits] in China and all exporters and reexporters, worldwide involved in the export of computers, servers, and ICs to China, will need to assess the new US export controls,” the firm said. It also said new U.S. person restrictions will make it “very difficult, if not impossible, for US Persons (citizens, permanent residents, refugees, asylees) to work in engineering R&D or provide technical support for Chinese companies engaged in the semiconductor, advanced computing, and supercomputer fields.”