Update For The New BIS Semiconductor Export Restrictions: The Temporary General License Has Expired

The Temporary General License granted under the new export restrictions on certain advanced computing products and semiconductor manufacturing items ("New Restrictions") in the U.S. Export Administration Regulations (EAR) has expired on April 7, 2023. Following the expiration of the Temporary General License, companies throughout the world will have to fully comply with the New Restrictions regarding the export, reexport, in-country transfers and exports from abroad to or within the PRC or Macau of the aforementioned products and related services, which will also likely create good opportunities to see how the BIS will interpret and enforce the New Restrictions.

The New Restrictions, as promulgated by the U.S. Bureau of Industry and Security (BIS) on October 7, 2022, is an attempt by the U.S. government to prevent a perceived rival in the PRC from using advanced computing technologies for the purpose of "military modernization" and "human rights abuses", among other