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BIS Extends Temporary Export Controls on Geospatial Artificial Intelligence Software

The Commerce Department’s Bureau of Industry and Security (BIS) issued an interim final rule (“Rule”) extending the temporary 0Y521 series export controls on software specially designed to automate the analysis of geospatial imagery, issued in January 2020. The Rule, which applies to geospatial imagery software specially designed for training a “Deep Convolutional Neural Network” to automate the analysis of geospatial imagery and point clouds (“Geospatial AI Software”), is effective from January 6, 2021 through January 6, 2022. A license is required for the export, reexport and in-country transfers of those items to all destinations, except Canada.

On January 6, 2020, BIS amended the Export Administration Regulations (EAR) with an interim final rule to add the Geospatial AI Software to the 0Y521 Temporary Export Control Classification Numbers (ECCN) Series as 0D521, because “it may provide a significant military or intelligence advantage to the United States or because foreign policy reasons justify control.” The U.S. government intended to raise its proposal for multilateral controls at the Wassenaar Arrangement in 2020 but the annual plenary was not held due to the pandemic.

Items classified under the 0Y521 series are controlled for regional stability (RS) Column 1 reasons, with a case-by-case license application review policy. The only license exception available for these items 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), as specified.

Thompson Hine LLP - Joyce Rodriguez

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