US Technology Controls: Emerging Technologies, Cloud & Deemed Exports

Introduction

Emerging technologies — including artificial intelligence,quantum computing, semiconductor manufacturing equipment, and advancedmaterials — have become a central battleground in US export control policy. Thecontrols are evolving rapidly, with BIS issuing new rules that expandrestrictions on advanced chips, AI, and foundational technologies. Thisadvanced course examines the cutting edge of US technology controls, includingthe treatment of cloud computing, software, and deemed exports, and explores howcompliance teams can keep pace with a fast-moving regulatory environment.

Who ThisCourse Is For

This course is designed for senior export compliance managers,trade counsel, technology policy professionals, and compliance teams atsemiconductor, software, AI, cloud, and advanced manufacturing companies.Participants should have a solid understanding of EAR fundamentals.

WhatYou'll Learn

•      The policy rationale for controls on emerging andfoundational technologies

•      Current BIS rules on advanced computing chips, AI, andsemiconductors

•      The Foreign Direct Product Rule: scope, conditions, andrecent expansions

•      Cloud computing and Software as a Service under the EAR

•      Deemed export controls and technology transferobligations

•      The Entity List and the Military End-User Rule in thetechnology sector

•      Compliance strategies for technology companies in arapidly changing environment

CourseStructure

Format: Live onlinesession with Q&A, also available as on-demand recording

Duration: 2 hours

Level: Advanced

Assessment: No formalassessment — attendance certificate issued on completion

Technical Requirements

This course is compatible with most operating systems andmodern web browsers. Live sessions are delivered via video conferencing.On-demand recordings are accessible via the course platform. A stable internetconnection is recommended. If you experience access issues, please contact yourorganisation's IT department or the course provider.

Course Content

1. The Policy Context

•      Technology competition and export controls as geopoliticaltools

•      The Export Control Reform Act and the 'emergingtechnologies' mandate

•      BIS advance notice of proposed rulemaking onfoundational technologies

•      The US-China technology competition: legislative andregulatory response

2. Advanced Computing andSemiconductor Controls

•      The October 2022 and subsequent BIS rules on advancedchips

•      ECCNs for advanced computing items and relatedtechnology

•      Country-specific restrictions and destination controls

•      Controls on semiconductor manufacturing equipment (SME)

3. The Foreign Direct ProductRule

•      Basic FDPR: original scope and application

•      Huawei FDPR and Advanced Computing FDPR

•      Applying the FDPR to foreign-made products containingUS technology

•      Practical compliance challenges for non-USmanufacturers

4. Cloud Computing and SoftwareControls

•      When does cloud access constitute an export under EAR?

•      Controlling access to encryption software and sourcecode

•      Software as a Service: compliance obligations forproviders

•      Data localisation and geofencing as compliance tools

5. Deemed Exports andTechnology Transfer

•      Deemed export rules for technology and source code

•      Managing foreign national access to controlledtechnology

•      Technology Control Plans: design and implementation

•      Case example: a deemed export investigation

6. Building a ComplianceProgramme for Tech Companies

•      Integrating export controls into product developmentand engineering

•      Training for R&D, engineering, and product teams

•      Staying current: monitoring BIS regulatory updates

•      Voluntary self-disclosure in a technology enforcementcontext

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