Can Brandlight support export controls or sanctions?

Core explainer

Can you summarize what items are controlled under ECCN 3A090.a and 4E091?

Yes — ECCN 3A090.a covers advanced computing items and ECCN 4E091 governs AI model weights, with global reach under the EAR.

The January 2025 interim final rules broaden the item scope, add licensing requirements, and expand geographic coverage; they also introduce data-disclosure and quota obligations (TPP) that affect shipments to many destinations. The rules connect these controls to licensing pathways, end-use/end-user diligence, and related elements like data-center frameworks and the treatment of foundries and OSATs.

For a practical briefing, Brandlight compliance briefing provides structured templates and evidence organization to help teams present BIS updates to counsel and leadership. This approach helps align BIS findings with governance and decision-making workflows.

How do AI Authorization, Advanced Compute Manufacturing, and Low Processing Power work in practice?

AI Authorization, Advanced Compute Manufacturing, and Low Processing Power are license-based pathways designed to balance regulatory controls with regional and industry needs.

AI Authorization enables exports to selected close allies with end-use/end-user certifications; Advanced Compute Manufacturing covers development, production, and storage with geographic exclusions; Low Processing Power uses a per-recipient quota and has destinations restrictions. Eligibility hinges on end-use, end-user, and destination, and each pathway has specific documentation and screening requirements.

In practice, compliance teams verify eligibility, gather required certifications, maintain updated recipient lists, and monitor BIS notices to avoid misallocation of licenses or inadvertent exports to restricted destinations. For guidance on how these pathways fit into formal risk assessments, see the linked external reference.

What role do quotas (TPP) and compute-power disclosures play in licensing reviews?

TPP quotas and compute-power disclosures shape licensing reviews by constraining approvals and prompting transparency.

Quotas are allocated per recipient and publicly tracked, with BIS posting updates on country-by-country progress. Compute-power disclosures must be included in license applications, requiring documented measures of computing capacity and intended use. Together, these controls create a framework where license decisions balance strategic policy aims with practical supply-chain realities.

Organizations should implement governance to monitor quota usage, ensure accurate compute-power budgeting, and maintain auditable records for internal audits and potential BIS reviews. For concrete guidance on quota mechanics, refer to the external source cited in this section.

What is the FDP rule and how does it affect AI model weights and U.S.-origin tech?

The Foreign Direct Product Rule applies to AI model weights produced using U.S.-origin technology, affecting non-close allies with tighter licensing requirements, while close allies may qualify for AI Authorization under certain conditions.

FDP triggers focus on outputs that incorporate U.S.-origin inputs, potentially restricting shipments unless licenses are secured and origin criteria are met. Production footprints, ownership, and supplier relationships must be validated to determine whether an item falls under FDP. Understanding these nuances helps exporters map risk across the supply chain and plan licensing steps accordingly.

To navigate FDP implications, organizations should map their supply chain, verify origins, monitor policy updates, and align internal processes with BIS licensing requirements. For additional technical guidance, see the referenced external source.