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ARTICLE · 28 JUNE 2024

Growing Technology Supply Chain Risks: Kaspersky Lab Software Banned In First Use Of ICTS Supply Chain Prohibition

Crowell & Moring LLP
Crowell & Moring LLP
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Crowell & Moring LLP

Crowell & Moring LLP

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Starting July 20, 2024, Kaspersky is prohibited from entering into any new agreement with U.S. persons, which includes U.S. citizens or residents located outside the United States...

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What You Need to Know

  • Key takeaway #1

    Starting July 20, 2024, Kaspersky is prohibited from entering into any new agreement with U.S. persons, which includes U.S. citizens or residents located outside the United States, for its cybersecurity/anti-virus software, and will not be able to provide any software or updates after September 29, 2024. Additionally, exports (of items subject to the EAR) to Kaspersky affiliates are now prohibited and dealings with certain leaders of Kaspersky are prohibited for all U.S. persons.
  • Key takeaway #2

    While this is the U.S. Department of Commerce's first use of the Information and Communications Technology and Services (ICTS) regulations to impose a prohibition on an entity from supplying its software to U.S. persons, this determination serves as a blueprint as to how Commerce might use this authority again.

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