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Articles by Benjamin Cote
Fall Cleaning at DDTC: Six ITAR Rulemakings in Three Weeks Reshape Country Policies and Trim the USML
In just a three-week period starting in September, the State Department’s Directorate of Defense Trade Controls (DDTC) published six rulemakings that make or propose notable changes to the International Traffic in Arms Regulations (ITAR).
Fall Cleaning at DDTC: Six ITAR Rulemakings in Three Weeks Reshape Country Policies and Trim the USML
In just a three-week period starting in September, the State Department’s Directorate of Defense Trade Controls (DDTC) published six rulemakings that make or propose notable changes to the International Traffic in Arms Regulations (ITAR).
Fall Cleaning at DDTC: Six ITAR Rulemakings in Three Weeks Reshape Country Policies and Trim the USML
In just a three-week period starting in September, the State Department’s Directorate of Defense Trade Controls (DDTC) published six rulemakings that make or propose notable changes to the International Traffic in Arms Regulations (ITAR).
State Department Eases Export Controls on Survivability-Enhanced Aircraft: Key Takeaways
On August 28, 2026, the Directorate of Defense Trade Controls (DDTC) published an interim final rule (IFR) easing export controls on certain survivability-enhanced aircraft under the International Traffic in Arms Regulations (ITAR). This action substantially relaxes ITAR controls on aircraft that have been modified to incorporate aircraft survivability equipment (ASE), and to exclude from ITAR authorization requirements certain reexports and temporary imports of ASE.
State Department Eases Export Controls on Survivability-Enhanced Aircraft: Key Takeaways
On August 28, 2026, the Directorate of Defense Trade Controls (DDTC) published an interim final rule (IFR) easing export controls on certain survivability-enhanced aircraft under the International Traffic in Arms Regulations (ITAR). This action substantially relaxes ITAR controls on aircraft that have been modified to incorporate aircraft survivability equipment (ASE), and to exclude from ITAR authorization requirements certain reexports and temporary imports of ASE.
Spotlighting US export controls amid BIS crackdown on semiconductors in China
The United States asserts jurisdiction over US-origin products and technology anywhere in the world regardless of whether a US person is involved in a transaction. The principal distinction between US sanctions and US export controls is that US sanctions generally apply to US persons, while US export controls apply to US products and technology.
The UAE Joins United States’ Closest Export Control Partners: Key Takeaways from the BIS Final Rule
Effective immediately, the United Arab Emirates has been removed from Country Groups D:3 and D:4 and added to Country Group A:5. This new country group designation allows exports of items controlled for chemical, biological or missile technology reasons to qualify for license exceptions that were previously unavailable to the UAE under its former Country Group classification.
The UAE Joins United States’ Closest Export Control Partners: Key Takeaways from the BIS Final Rule
Effective immediately, the United Arab Emirates has been removed from Country Groups D:3 and D:4 and added to Country Group A:5. This new country group designation allows exports of items controlled for chemical, biological or missile technology reasons to qualify for license exceptions that were previously unavailable to the UAE under its former Country Group classification.
GAO Holds Commerce’s Non-Enforcement of the AI Diffusion Rule Is a “Rule” Subject to the Congressional Review Act
Takeaways The decision sharpens the line between permissible enforcement discretion and across-the-board policies that effectively suspend regulations. The AI Diffusion Rule remains legally in effect as of today’s date without a legally valid action to exempt compliance.
Widening FOCI: DOD Issues Proposed Rule Expanding FOCI Review and Mitigation to Unclassified Prime and Subcontracts
Takeaways The rule would cover Department of Defense/War unclassified prime contracts and subcontracts—at any tier—valued at $5 million. This change is estimated to impact more than 37,000 entities, a nearly 20-fold expansion. Covered offerors, contractors and subcontractors must file and update their SF328 and beneficial ownership information in the National Industrial Security System to remain eligible.
Drone in the USA: FCC Seeks Comment on New Flight Plan for UAS and C-UAS Commercialization in the United States
Takeaways The FCC released a public notice seeking comment on a wide range of proposed regulatory reforms intended to accelerate domestic drone deployment, including expanded spectrum access, licensing reform, and improved mechanisms for interagency coordination. This proceeding is part of the Trump administration’s government-wide mandate to promote domestic drone commercialization and production and reduce U.S. reliance on foreign-manufactured systems.
FCC Announces Seminal Enforcement Action for Violating Team Telecom Commitments | JD Supra
Takeaways After noticing a gap in compliance, a U.S. Department of Justice National Security Division referral resulted in the first-ever U.S. Federal Communications Commission enforcement action for violating commitments to Team Telecom. To resolve the investigation, Marlink entered a consent decree with the FCC, agreeing to pay a $175,000 voluntary contribution, implement a robust compliance plan, and revise internal procedures and controls on foreign employees.
FCC Implements Categorical Prohibition on All Foreign-Produced UAS and UAS Critical Components | JD Supra
Takeaways Acting on a National Security Determination, the U.S. Federal Communications Commission adopted a first-of-its-kind categorical prohibition on the importation, marketing, and sale of all foreign-produced UAS and UAS critical components, effective immediately.
Executive Orders Aim to Boost Drones, eVTOLs, Counter-UAS and Supersonic Flight | JD Supra
Drones and eVTOLS EO. Promotes U.S. “development, commercialization, and export” of drones and creates eVTOL integration pilot program. Counter-UAS EO. Directs the U.S. Government to find ways to safeguard critical infrastructure, expand federal authority to engage in counter-UAS and make it easier for state and local authorities to detect and identify UAS operations. Supersonic Flight EO.
Spotlighting US export controls amid BIS crackdown on semiconductors in China
This is an Insight article, written by a selected contributor as part of GIR's co-published content. Read more on Insight The United States asserts jurisdiction over US origin products and technology anywhere in the world regardless of whether a US person is involved in a transaction. The principal distinction between US sanctions and US export controls is that US sanctions generally apply to US persons, while US export controls apply to US products and technology.
847 Awaiting Takeoff: DCSA Issues Guidance on Expanded Scope of FOCI Assessments | JD Supra
Section 847, which will expand foreign ownership, control or influence requirements to non-classified contracts, is on track for implementation in 2026. Section 847 of the National Defense Authorization Act for FY 2020 directs the Department of Defense (DoD) to move forward with proposing a new Defense Federal Acquisition Regulation Supplement (DFARS) rule that would expand the scope of companies subject to its foreign ownership, control, and influence (FOCI) evaluations.
USTR Section 301 Shipbuilding Reprised | JD Supra
On April 17, 2025, the Office of the U.S. Trade Representative (USTR) published a Notice of Action and Proposed Action in its Section 301 investigation finalizing aspects of USTR’s responsive measures to China’s targeting for dominance of the maritime and shipbuilding industries. The Notice narrows the fees and service restrictions USTR proposed in March, as discussed in our previous article.
DOD agency alerts contractors on expanded scope of foreign-influence assessments
(May 22, 2025) - Attorneys at Pillsbury Winthrop Shaw Pittman LLP discuss a potential rule that would require more companies to disclose any foreign ownership, control or influence when bidding for a U.S. defense contract. Section 847, which will expand foreign ownership, control or influence requirements to non-classified contracts, is on track for implementation in 2026.
Comparing Developments in U.S. and EU Strategies to Combat Forced Labor | JD Supra
In recent years, a multinational focus on preventing forced labor within supply chains has shaped due diligence requirements for companies worldwide. Recent changes to global policies and potential shifts in enforcement appetite are set to reshape these requirements once again.
The Battle of the Shipyards: USTR Proposals Would Require U.S.-Flagged and U.S.-Built Vessels, Impose Fees on Operators of Chinese Vessels | JD Supra
On February 21, 2025, the Office of the U.S. Trade Representative (USTR) announced a proposal to: (i) require that exporters of U.S. goods use U.S.-flagged and U.S.-built vessels for an increasing percentage of their exports; and (ii) impose service fees on Chinese vessel operators and other operators that use or contract for the use of Chinese-built vessels.
Trump 2.0: U.S. Imposes Tariffs on Key Trading Partners | JD Supra
After months of anticipation, on February 1, 2025, President Trump announced the imposition of significant tariffs on Mexico, Canada, and China through three Executive Orders (EOs). While additional details are expected to be published in the Federal Register in days to come, the tariffs mark a significant shift in U.S. trade policy. Key points are outlined below.
Trump 2.0: U.S. Imposes Tariffs on Key Trading Partners
After months of anticipation, on February 1, 2025, President Trump announced the imposition of significant tariffs on Mexico, Canada, and China through three Executive Orders (EOs). While additional details are expected to be published in the Federal Register in days to come, the tariffs mark a significant shift in U.S. trade policy. Key points are outlined below.
FHWA Rescinds Longstanding Buy America Waiver for Manufactured Products | JD Supra
On January 13, 2025, the U.S. Federal Highway Administration (FHWA) issued a final rule terminating a long-standing exception to “Buy America” domestic content requirements for manufactured products used in agency-funded projects.
BIS Proposes Rules to Protect from Chinese and Russian Connected Vehicle Technology | JD Supra
On September 23, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released for public inspection a Notice of Proposed Rulemaking that seeks to prohibit the sale or import of connected vehicles (CVs) with certain hardware and software that have a sufficient nexus to the People’s Republic of China (PRC) or Russia.
BIS Proposes Rules to Protect from Chinese and Russian Connected Vehicle Technology
On September 23, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released for public inspection a Notice of Proposed Rulemaking that seeks to prohibit the sale or import of connected vehicles (CVs) with certain hardware and software that have a sufficient nexus to the People’s Republic of China (PRC) or Russia.
Photonics | Free Full-Text | In-Vivo Dosimetry for Ultra-High Dose Rate (UHDR) Electron Beam FLASH Radiotherapy Using an Organic (Plastic), an Organic-Inorganic Hybrid and an Inorganic Point Scintillator System
All articles published by MDPI are made immediately available worldwide under an open access license. No special permission is required to reuse all or part of the article published by MDPI, including figures and tables. For articles published under an open access Creative Common CC BY license, any part of the article may be reused without permission provided that the original article is clearly cited. For more information, please refer to https://www.mdpi.com/openaccess.
Department of Commerce Releases Five Products to Help Guide AI Development | JD Supra
Takeaways The Department of Commerce released three final guidance documents incorporating public comments from earlier this spring which provide recommendations for managing AI risk, securing AI software development processes, and developing global AI norms and standards.
Spotlighting export controls in the United States
This is an Insight article, written by a selected partner as part of GIR's co-published content. Read more on Insight The United States asserts jurisdiction over US origin products and technology anywhere in the world regardless of whether a US person is involved in a transaction. The principal distinction between US sanctions and US export controls is that US sanctions generally apply to US persons, while US export controls apply to US products and technology.
USTR Calls for Stakeholder Comments Following the Report on the Four-Year Review of the Section 301 Tariffs | JD Supra
TAKEAWAYS On May 22, USTR followed up the recommendations in its March 14 report with specific proposals for increases in Section 301 tariffs. There will be an exclusion process allowing interested parties to request temporary exclusions for certain categories of machinery used in domestic manufacturing, but no more general exclusion request procedure was announced. USTR has requested comments from interested stakeholders by June 28, 2024.
USTR Calls for Stakeholder Comments Following the Report on the Four-Year Review of the Section 301 Tariffs
On May 14, 2024, the U.S. Trade Representative (USTR) published the Four-Year Review of Actions Taken in the Section 301 Investigation (“Report”), which addresses the four-year review of China-related tariffs under Section 301 of the Trade Act of 1974, as amended (“Trade Act”) (19 U.S.C. 2411). Our previous alert on this report is available here.
USTR Issues Long Awaited Report on the 4-Year Review of the Section 301 Tariffs | JD Supra
On May 14, 2024, the U.S. Trade Representative (“USTR”) published the Four-Year Review of Actions Taken in the Section 301 Investigation (“Report”), which addresses the four-year review of China-related tariffs under Section 301 of the Trade Act of 1974, as amended (“Trade Act”) (19 U.S.C. 2411). Our previous alert on the 2018 Section 301 Investigation findings is available here.
USTR Issues Long Awaited Report on the 4-year review of the Section 301 Tariffs
On May 14, 2024, the U.S. Trade Representative (“USTR”) published the Four-Year Review of Actions Taken in the Section 301 Investigation (“Report”), which addresses the four-year review of China-related tariffs under Section 301 of the Trade Act of 1974, as amended (“Trade Act”) (19 U.S.C. 2411). Our previous alert on the 2018 Section 301 Investigation findings is available here.
State Department Proposes Exempting Australia, UK from Certain Defense Related Export Controls | JD Supra
On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering activities between or among authorized users in the United States, United Kingdom (UK) and Australia.
State Department Proposes Exempting Australia, UK from Certain Defense Related Export Controls
On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering activities between or among authorized users in the United States, United Kingdom (UK) and Australia.
Further Enhancing Australia, United Kingdom, United States (AUKUS) Trilateral Security Partnership through Export Controls | JD Supra
On April 19, 2024, the Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule reducing export control licensing requirements for Australia and the United Kingdom (UK) as a means to further strengthen the AUKUS trilateral security partnership between the three countries. With this rule, Australia and the UK will have nearly the same liberal licensing treatment under the Export Administration Regulations (EAR) as Canada.
Further Enhancing Australia, United Kingdom, United States (AUKUS) Trilateral Security Partnership through Export Controls
On April 19, 2024, the Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule reducing export control licensing requirements for Australia and the United Kingdom (UK) as a means to further strengthen the AUKUS trilateral security partnership between the three countries. With this rule, Australia and the UK will have nearly the same liberal licensing treatment under the Export Administration Regulations (EAR) as Canada.
U.S. Increases Export Restrictions Against Nicaragua | JD Supra
The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the military end use and military end user restrictions.
Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement | JD Supra
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. TAKEAWAYS Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export control laws can apply to non-U.S. persons. The note emphasizes that U.S. agencies tasked with overseeing compliance with sanctions and export controls are proactive in targeting offenders anywhere in the world.
U.S. Increases Export Restrictions Against Nicaragua
The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the military end use and military end user restrictions.
Congress Continues to Address AI in Bipartisan Fashion, Launching House AI Task Force as Latest Step | JD Supra
TAKEAWAYS House leadership announced the launch of the Task Force on Artificial Intelligence (AI), a bipartisan group that will develop a report outlining AI regulatory priorities and setting guiding principles to help shape the AI landscape. The goal of the AI Task Force is to identify a series of legislative proposals that have the potential to be approved by both chambers of Congress this year.
BIS Issues Additional Enhancements to Voluntary Self-Disclosure Process | JD Supra Original
Takeaways: On January 16, 2024, the Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) announced several updates to its Voluntary Self-Disclosure (VSD) process aimed at enhancing the program’s overall efficiency and effectiveness. These enhancements create a more streamlined disclosure process for minor violations, including through abbreviated narratives, quarterly bundled disclosures, and limiting the requirement to include a five-year lookback.
BIS Issues Additional Enhancements to Voluntary Self-Disclosure Process
Takeaways: On January 16, 2024, the Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) announced several updates to its Voluntary Self-Disclosure (VSD) process aimed at enhancing the program’s overall efficiency and effectiveness. These enhancements create a more streamlined disclosure process for minor violations, including through abbreviated narratives, quarterly bundled disclosures, and limiting the requirement to include a five-year lookback.
ISOO Guidance on Facility Security Clearances for Joint Ventures | JD Supra
On October 5, 2023, the National Archives Information Security Oversight Office (ISOO) released a joint notice to provide guidance on facility clearances for joint ventures (JVs) in the National Industrial Security Program (NISP). This guidance addresses the interaction of NISP requirements and an October 16, 2020 Small Business Administration (SBA) rule on JVs and also aims to clarify confusion arising from a Government Accountability Office (GAO) decision interpreting the SBA 2020 rule.
ISOO Guidance on Facility Security Clearances for Joint Ventures
On October 5, 2023, the National Archives Information Security Oversight Office (ISOO) released a joint notice to provide guidance on facility clearances for joint ventures (JVs) in the National Industrial Security Program (NISP). This guidance addresses the interaction of NISP requirements and an October 16, 2020 Small Business Administration (SBA) rule on JVs and also aims to clarify confusion arising from a Government Accountability Office (GAO) decision interpreting the SBA 2020 rule.
President Biden Issues Long-Awaited Executive Order on Safe, Secure and Trustworthy Artificial Intelligence | JD Supra
TAKEAWAYS The Executive Order creates new guidelines directed toward AI safety and security, privacy protections, equity and civil rights, consumers’ and workers’ rights, and innovation and competition.
White House Announces Plan To Boost AI Research And Deployment
TAKEAWAYS On May 23, the White House revealed three new steps advancing the research, development and deployment of AI technology nationwide. The Biden Administration has updated the National Artificial Intelligence R&D Plan for the first time since 2019 with a new emphasis on international collaboration and reaffirming the need to address the ethical implications and safety of AI.
White House Announces Plan to Boost AI Research and Deployment | JD Supra
TAKEAWAYS On May 23, the White House revealed three new steps advancing the research, development and deployment of AI technology nationwide. The Biden Administration has updated the National Artificial Intelligence R&D Plan for the first time since 2019 with a new emphasis on international collaboration and reaffirming the need to address the ethical implications and safety of AI.
Congress Contemplates Creating A New Federal AI Regulatory Agency
TAKEAWAYS At a May 16 hearing of the Senate Judiciary Subcommittee on Privacy, Technology and the Law, members of Congress openly supported creating a new federal agency dedicated to the monitoring and licensing of artificial intelligence. The positions echo testimony of Sam Altman (CEO of OpenAI—creator of ChatGPT), who discussed ways for an agency to issue licensing requirements for AI program.
DFARS Proposed Export Controls Rule Would Require Supplying DCMA with Copy of Relevant Export Authorizations | JD Supra
On March 22, 2023, the Department of Defense (DoD) published a proposed rule to amend Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.225-7048. This amendment would implement an additional export control requirement for certain contractors.
Commerce Issues Guidance on Recent Advanced Computing and Semiconductor Manufacturing Controls for China | JD Supra
On October 28, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued guidance on its October 7, 2022 interim final rule (Rule) that imposed new export controls on certain advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and semiconductor manufacturing items exported to the People’s Republic of China (PRC). Comments on the Rule will be accepted until December 12, 2022. Our previous blog post on the Rule may be found here.
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