WilmerHale – BIS issued an interim final rule controls targeting integrated circuits (“ICs”) fabricators. BIS is concerned that some IC designers have misrepresented the performance capabilities and intended end use of their designs to third-party fabricators contracted to manufacture the ICs. This makes it difficult for the fabricators to determine whether the correct Export Control Classification Number (“ECCN”) of the ICs they are producing and the corresponding restrictions.
Source:
- Wilmer Cutler Pickering Hale and Dorr LLP: BIS Issues Export Control Compliance Requirements for Semiconductor Fabricators
