The Department of Commerce's ("Commerce") Bureau
of Industry and Security ("BIS") has prohibited a broad
range of transactions involving Kaspersky Security Network
("Kaspersky") anti-virus and cybersecurity software,
citing vulnerabilities they create for U.S. national security.
This marks the first use of the Information and Communication
Technology and Services authorities (Executive Order 13873 and its
associated regulations) ("ICTS authorities") to restrict
a specific party's products or services. It highlights a risk
that companies should consider in assessing global operations.
BIS implemented the prohibition on Kaspersky products and
services via a June 24, 2024, final determination. BIS concluded
that the risk to U.S. national security from Kaspersky products and
services could not be mitigated by measures short of prohibiting
transactions in the United States or with U.S. persons. BIS
clarified that this prohibition also applies to any updates to
existing
