Background

The Bureau of Industry and Security has extended again, through Jan. 5, 2023, an interim final rule making certain items subject to the Export Administration Regulations and imposing a license requirement for the export and reexport of those items to all destinations except Canada.

This rule adds software specially designed for training a deep convolutional neural network to automate the analysis of geospatial imagery and point clouds to the 0Y521 temporary ECCN series as 0D521 following a determination that such software may provide a significant military or intelligence advantage to the U.S. or because foreign policy reasons justify export control.

As a result, this software is controlled for regional stability Column 1 reasons with a case-by-case license application review policy. The only license exception available for this software at this time is for exports, reexports, and transfers (in-country) made by or consigned to a department or agency of the U.S. government (license exception GOV).

BIS notes that items classified under ECCN 0Y521 remain there for one year unless they are reclassified under a different ECCN or the 0Y521 classification is extended. BIS may extend that classification for two one-year periods provided that the U.S. government submits a proposal for export control to the relevant multilateral regime(s) to obtain multilateral controls over the item. Further extension may occur only if BIS determines that it is in the national security or foreign policy interests of the U.S.

For more information, please contact attorney Kristine Pirnia via email.

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