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ARTICLE · 05 JUNE 2026

BIS Publishes Guidance Regarding License Requirements For Advanced Computing Items

Holland & Knight
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The U.S. Department of Commerce Bureau of Industry and Security issued rare weekend guidance clarifying export license requirements for advanced computing items destined...

United StatesInternational Law
Matt Rosenbaum
Matt Rosenbaum
Manny Levitt
Manny Levitt
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The U.S. Department of Commerce Bureau of Industry and Security (BIS) issued guidance on Sunday, May 31, 2026 – a rare weekend release – regarding enforcement of license requirements for certain "advanced computing" items. The guidance clarified that a license is required to export advanced computing items destined to entities headquartered in Country Group D:5 (which includes China) or Macau or to entities with an ultimate parent company headquartered in Country Group D:5 or Macau – even if the entities themselves are located outside Country Group D:5 or Macau.

Background

BIS's guidance comes at a time of uncertainty surrounding the regulatory landscape for certain advanced computing exports. In a May 2025 press release, BIS announced a rescission of the Artificial Intelligence (AI) Diffusion Rule issued in January 2025 under the Biden Administration. Among other new requirements, the AI Diffusion Rule imposed a worldwide license requirement for certain advanced computing

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