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ARTICLE · 17 JANUARY 2025

BIS Announces Worldwide Export Controls On Advanced Chips And AI Models

Simpson Thacher & Bartlett LLP
Simpson Thacher & Bartlett LLP
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Simpson Thacher & Bartlett LLP

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On January 13, 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") issued an interim final rule that significantly expands export controls around artificial intelligence ("AI") and advanced computing chips.

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On January 13, 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") issued an interim final rule that significantly expands export controls around artificial intelligence ("AI") and advanced computing chips. Entitled "Framework for Artificial Intelligence Diffusion," these new rules restrict the export, reexport, or in-country transfer of sophisticated AI models by requiring a license to export the most advanced closed-weight AI models. Model weights, numerical values that represent the strength of the connections between variables in an AI model, will now be controlled by U.S. export controls even where those model weights are for an AI model that was: (1) trained entirely outside the United States, (2) by non-U.S. personnel, and (3) using cloud computing centers outside the U.S. Indeed, these new rules govern the export of any AI model trained above a certain level of computational operations using advanced integrated chips subject to U.S.

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