On January 19, 2021 the U.S. Department of Commerce ("Commerce") published an interim final rule (IFR) to implement a May 15, 2019 Executive Order (EO) on "Securing the Information and Communications Technology and Services Supply Chain." The IFR creates a framework for Commerce to identity and handle "ICTS Transactions" that "involve foreign adversaries" and may pose a U.S. national security risk. The IFR also designates China (including Hong Kong), Cuba, Iran, North Korea, Russia and Venezuela's Maduro regime as "foreign adversaries." The rule is effective March 22, 2021 with comments due the same day. However, some uncertainty exists as to whether the Biden Administration will alter, revoke or delay the IFR before then.
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