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ARTICLE · 08 APRIL 2024

Deadline To Comment On Proposed Rules Impacting Infrastructure As A Service Providers Approaching

Foley Hoag LLP
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New proposed rule by the Department of Commerce's Bureau of Industry and Security ("BIS") could subject U.S. cloud service providers...

United StatesInternational Law
Luciano Racco
Luciano Racco
Chawkat Ghazal
Chawkat Ghazal
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Key Takeaways:

  • New proposed rule by the Department of Commerce's Bureau of Industry and Security ("BIS") could subject U.S. cloud service providers and their foreign resellers to data collection and reporting requirements.
  • If rule becomes final, U.S. Infrastructure as a Service ("IaaS") providers and their foreign resellers will have one year to develop a Customer Identification Program to collect and maintain personal identifying information about their current and prospective customers.
  • The proposed rule would require U.S. IaaS providers and their foreign resellers to submit reports about transactions with foreign persons where U.S. IaaS products are used to train large AI models with potential capabilities that could be used in malicious cyber-enabled activity.

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