New EAR Controls Prompt Considerations for Banks Serving Semiconductor Industry Clients

A presentation made at a recent meeting of LC bankers offered insights regarding specialists’ understanding of US regulatory requirements with respect to serving semiconductor industry clients.

In December 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) released additional rules including some designed to strengthen export controls for restricting the capability of People’s Republic of China to produce advanced semiconductors for military applications. These rules, effective 2 December with a delayed compliance date of 31 December 2024 for certain controls, impose controls on many types of semiconductor equipment and technology.

On 15 January 2025, BIS then released rules that update export controls on advanced computing semiconductors designed to mitigate efforts by China to obtain high-end advanced computing semiconductors integral for development and production of technologies such as AI used in military applications. The rules reinforce and build on controls put in place over the past three years. The BIS press release announcing these updates urges exporters to carefully review the full text of the rule which makes changes to existing provisions of the Export Administration Regulations (EAR).

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