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The U.S. Department of Commerce (“Commerce”) is quietly ramping up efforts to implement its wide-ranging rules on securing the supply chain for information and communications technology and services (“ICTS”), which went into effect in March 2021. These rules empower Commerce to conduct national security reviews of ICTS transactions, including acquisition of ICTS from abroad and its deployment in the United States, where there is a nexus with a “foreign adversary” such as China or Russia.
These rules will impact companies involved in telecommunications, connected applications, software development, and emerging technologies, or with a nexus to critical infrastructure. In particular, the rules will be relevant in the context of cross-border development and acquisition of covered technology that is intended to be used in the United States or by U.S. persons.
Anthony Rapa is a partner at Blank Rome LLP and leads the firm’s National Security team. During his 15 years of practice, he has advised clients across a range of industries, including technology / software, semiconductors, automotive, and telecommunications, on international risk issues such as export controls, supply chain security, and economic sanctions. Please join Mr. Rapa as he discusses:
- The history and purpose of the ICTS rules [5 minutes]
- Types of ICTS transactions subject to review [7 minutes]
- Types of ICTS in scope of the rules [10 minutes]
- The Commerce Department’s review criteria [10 minutes]
- The Commerce Department’s review process [10 minutes]
- ICTS administration / enforcement to date [5 minutes]
- Compliance tips [8 minutes]
- Where we go from here [5 minutes]
Who Should Attend: In-house counsel, outside attorneys, compliance and other allied professionals with an interest in ICTS supply chain rules
Program Level: Update
Advanced Preparation: None
Blank Rome LLP