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Special Issues

  • BIS Extends Timeline for Authorized IC Designers

    On January 16, 2025, BIS published a rule titled "Implementation of Additional Due Diligence Measures for Advanced Computing Integrated Circuits; Amendments and Clarifications; and Extension of Comment Period", which included a timeline during which certain companies are considered authorized integrated circuit (IC) designers who can overcome a presumption of certain license requirements. On April 7, 2026, BIS extended this timeline until December 31, 2026. This extension will allow more time for companies to submit Approved IC Designer applications and allow BIS additional time to process these applications. 

    The text of the rule can be viewed here.

  • Cuba Export Controls SCP Updates

    BIS has issued two updates affecting License Exception Support for the Cuban People (SCP) under § 740.21. Effective March 4, 2026, BIS suspended SCP availability under § 740.21(b)(1) for any transaction involving the deposit of foreign funds into a Cuban‑owned bank, citing unacceptable risk of benefiting the Cuban government or its military and intelligence services. This suspension does not apply to transactions routed through third‑country financial institutions or to shipments already en route by March 4, 2026 if completed by April 3, 2026. BIS also updated guidance on SCP availability for transactions involving U.S.-origin gas and petroleum products to eligible Cuban private sector entities or individual consumers; qualifying transactions may proceed without a license.

    SCP Gas/Petroleum/Banks FAQ
    Cuba Export Control Guidance

  • Section 232 Investigations

    The Secretary of Commerce initiated investigations under Section 232 of the Trade Expansion Act of 1962 to determine the effects on the national security of imports of the following: 

    The posted Section 232 Inclusion Requests and their requested HTSUS Classifications can be found on Docket BIS-2025-0023 on Regulations.gov.

    Section 232 Investigations Homepage

    Section 232 Inclusions Processes

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