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ARTICLE · 14 JANUARY 2020

Commerce Department Publishes Interim Final Rule Controlling Geospatial Imagery Software For Training AI

Companies anxiously awaiting the release of "emerging technology" export control rules now have an initial interim rule indicating how the Department of Commerce Bureau of Industry and Security (

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Companies anxiously awaiting the release of "emerging technology" export control rules now have an initial interim rule indicating how the Department of Commerce Bureau of Industry and Security (BIS) is likely to proceed. Specifically, the interim rule related to software for training AI appears to be a narrowly tailored rule covering a specific type of AI software related to specific national security concerns involving geospatial imagery. While there are some questions on the scope of what is covered by "geospatial imagery," comments on the rule due on March 6 will allow industry to provide input and hopefully obtain formal clarification once the final rule is issued. Additionally, the interim rule highlights that the new "emerging technology" rules will not be a "one and done" but rather a rolling series of rules on specific technologies warranting control.

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