Christopher Timura recently discussed the future of semiconductor export licensing with Global Investigations Review. He emphasized that despite the U.S. Department of Commerce’s decision to rescind the Biden-era AI diffusion rule, semiconductor export licensing requirements are expected to remain. Timura stated, “I wouldn’t necessarily think that just because a quota isn’t in place and there aren’t limits, doesn’t mean there aren’t licensing requirements that are still applied to these chips.”
The AI diffusion rule was withdrawn shortly before its implementation. The Department of Commerce argued that it would have “stifled American innovation and saddled companies with burdensome new regulatory requirements” while also potentially harming diplomatic relations by downgrading countries to “second-tier status.”
Timura noted that the Trump administration is likely to continue addressing illegal diversions of U.S. technology through new export controls. He mentioned, “There might ultimately be uncertainty for particular jurisdictions as to whether the chips will be allowed into those countries at all.” Furthermore, he pointed out that countries previously categorized under more restrictive tiers may still face challenges in obtaining licenses due to a “strike against them” in licensing decisions.
