The latest U.S. semiconductor-related export restrictions represent a strengthening of controls on China along with a “massive” expansion of foreign direct product rule restrictions, but they also include some head-scratching loopholes that chip firms will exploit, semiconductor policy researchers said this week.

A new set of U.S. export controls announced this week target a range of semiconductor manufacturing equipment, chip software tools, high-bandwidth memory and more, including by introducing new license obligations on certain foreign-made tools that the Bureau of Industry and Security said can be used by China to make advanced chips for its military. BIS also added more than 100 entities to the Entity List, most based in China, for aiding Beijing's military technology goals.

Although President-elect Donald Trump has vowed to dismantle the federal bureaucracy in Washington, a key architect of recent DOJ export control and sanctions initiatives believes those efforts will echo through the next administration.

A key portion of the conference hosted earlier this month by the Committee on Foreign Investment in the U.S. focused on the committee’s increasing scrutiny of fund structures and identifying the roles of limited partners in investment transactions, law firms said this month.

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The U.S. government likely needs to change the way it's trying to convince Japan, the Netherlands and other allies to impose export controls on a broader set of semiconductor manufacturing equipment, including by potentially offering them economic incentives and loosening some existing export restrictions, researchers said in a new report this month. The authors also said the Bureau of Industry and Security should survey American chip toolmakers to better understand global chip markets, which can help it maximize the effectiveness of its current export restrictions.

The Bureau of Industry and Security soon will place new export controls over certain scientific testing and industrial processing equipment destined to Pakistan that had not previously faced license requirements, saying the items have been diverted through Pakistan to companies on the Entity List.

The EU is expecting European parent companies working in certain sensitive sectors to take “substantial actions” to make sure their non-EU subsidiaries aren’t helping Russia or Belarus evade sanctions, regardless of the size of the parent company, the EU said in new guidance.

An Indian national violated U.S. export controls by lying on at least one export application for dual-use aerospace technology, telling the government the item would be exported to India when he actually planned to send it to Russia, according to a DOJ indictment unsealed last week and the sworn affidavit of a Bureau of Industry and Security special agent.

European companies are looking for clarity around new rules that may require them to boost due diligence efforts among their non-EU subsidiaries and insert language in contracts that bars reexports of sensitive goods to Russia and Belarus, lawyers said this week.