Regulatory Advisory on Evolving U.S. AI Export Controls

Provided ongoing strategic counsel to a U.S. AI infrastructure company navigating the rapidly shifting landscape of export controls on advanced computing hardware, including GPUs subject to heightened controls under the Export Administration Regulations. Analyzed the legal implications of the January 2025 worldwide licensing regulation (“AI Diffusion Rule”), its subsequent rescission, and the regulatory uncertainty created by the absence of a formal replacement regulation. Prepared a detailed legal memorandum assessing the viability of a new licensing pathway for GPU exports to China under specific eligibility criteria and impacts of new tariffs on semiconductor imports.  Monitored and advised on proposed legislation including the Chip Security Act, the Remote Access Security Act and the MATCH Act, assessing their potential impact on the client's global operations, deal pipeline and future impacts to long-term agreements.