On 7 October 2022, the US Department of Commerce, Bureau of Industry and Security (“BIS”) published an interim final rule implementing a series of controls on advanced computing and semiconductor technology destined to China.1 In the Supplementary Information section of the 7 October rule, BIS explained that “due to the urgent need for this rule to counter China’s actions, it will not be published as a Section 1758 technology rule, which would include a notice and comment period (50 USC. 4...
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