U.S. Strengthens Export Controls on Advanced Computing Items, Semiconductor Manufacturing Items | Insights | Holland & Knight
Summary
Based on these findings, BIS modified the FDP Rule to impose additional controls on certain SME items, which are used for production of advanced-node ICs and present a national security risk. To mitigate risks, the exception includes: pre-shipment notifications, annual end-use confirmation reports and monitoring of installed equipment, prohibition of exports for advanced-node IC production and detailed requirements for facilities to verify compliance with U.S. national security objectives. The IFR introduces new controls for High-Bandwidth Memory (HBM) due to its strategic importance in enabling advanced computing capabilities, particularly for applications in AI, machine learning and military systems. BIS provides limited license exceptions for HBM exports under specific conditions, such as to approved allied countries, ensuring compliance with international agreements and reducing supply chain disruption. For more information on the implications BIS rules or assistance with complying with export control regulations in such industries, please contact the authors or another member of Holland & Knights International Trade Group.