License Requirements and Exceptions
The Foreign Direct Product Rule, License CIV and APR: The Finer Points of Interpreting and Applying Recent Changes-and Managing Their Practical Impact
- Increasing number of foreign-made items captured by the EAR, including certain generic, commercial and off-the-shelf items
- What is entailed in the case-by-case review policy for foreign-made items that are capable of supporting the “development” or “production” of telecom systems, equipment and devices at only below the 5G level
- How should companies interpret the new Foreign Direct Product Rule?
- What are the prospects for more changes to the Foreign Direct Product Rule and/or BIS guidance?
- Aftermath of the expiration of the Huawei Temporary General License
- Impact of the elimination of license exception CIV?
- Status of BIS’ proposal to eliminate APR
- Securing flexible licensing replacements for CIV and APR
- When are items “produced or developed” by Huawei? What level of technical contribution does it take?