On December 29, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published a series of Frequently Asked Questions (FAQs) addressing comments received on the October 13, 2022 interim final rules that amended, and in some cases expanded, U.S. export restrictions on semiconductor manufacturing items and advanced computing items and end uses. The FAQs cover topics such as requirements to notify BIS under the Notified Advanced Computing (NAC) license exception, the definition of U.S. persons under the rule, and parameters for measuring die area.
Crowell will continue to monitor developments around these interim final rules.