Skip
    PLI PLUS

    On-Demand

    The Emergence of the ICTS Supply Chain Rules: Recent U.S. Commerce Department Actions Usher in the Age of Inbound Technology Regulation

    1-hour program
    Up to 1 credit

    Overview

    In 2024, the U.S. Department of Commerce (“Commerce”) has significantly ramped up activity under its regulations on Securing the Information and Communications Technology and Services Supply Chain (“ICTS”) (15 C.F.R. Part 791), which are intended to address threats to the U.S. technology supply chain from malign foreign actors. Specifically, 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 are relevant to companies involved in telecommunications, connected applications, network infrastructure, artificial intelligence, autonomous technology, and other emerging technologies, or with a nexus to critical infrastructure. In particular, Commerce has broad authority to investigate—and regulate—covered ICTS transactions involving (a) persons or property subject to U.S. jurisdiction, and (b) property in which a foreign person has an interest.

    This year, with new executive leadership in place to administer the ICTS program, Commerce has intensified its efforts to address national security threats to the ICTS supply chain. These actions have included issuance of a proposed rule regarding infrastructure as a service (“Iaas”), an advance notice of proposed rulemaking regarding connected vehicles, and the first-ever final rule banning certain technology under the ICTS program.

    Anthony Rapa is a partner at Blank Rome LLP and leads the firm’s National Security team. During his 17 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 [7 minutes]
    • Commerce Department review criteria [8 minutes]
    • Commerce Department review process [7 minutes]
    • ICTS rulemakings to date [9 minutes]
    • Proposed rule on connected vehicles [9 minutes]
    • Compliance tips [8 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

    Prerequisites: None

    Advanced Preparation: None



    Faculty:

    Anthony Rapa

    Blank Rome LLP

    Access your credit details

    You must add a license in order to access your credit details and see approval status for this program.

    Save on this program with an Individual Membership

    With a yearly Individual Membership, you get:

    • On-Demand Learning
    • Live Webcasts and Groupcasts
    • 400 PLI and SEC Institute Forums
    • Interactive Learning Center Programs
    Learn more

    Faculty

    Speaker

    Program Attorney

    Cookie Preferences