TGL Expiration Could Provide Insight Into BIS Chip Controls Implementation, Law Firm Says
The upcoming expiration of the Bureau of Industry and Security's temporary general license outlined in the China-related chip controls from October presents “good opportunities to see” how the agency will “interpret and enforce the new restrictions,” Lee, Tsai & Partners said in a recent client alert. The TGL expires April 7, when BIS has said it will begin reviewing license applications for activities that were covered by the TGL on a case-by-case basis (see 2301270026).
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Although many technology companies have been using the “grace period” granted by the TGL to “move their supply chain operations outside” of China, the law firm noted that “may not be feasible technologically or financially to do so for many others.” The firm urged companies to “keep a very close eye on how the BIS will apply” the new restrictions, which could bring some “needed clarity to the relevant key provisions after the expiration of the Temporary General License period.”