United States: International Law

The time has come. The U.S. Bureau of Industry and Security’s (“BIS”) Affiliates Rule that was postponed last year is slated to take effect November 10, 2026, barring another extension. The Rule was initially set to start November 10, 2025 but was extended for a year, effectively giving exporters one-year notice to conduct due diligence within its customer base to ensure compliance with the Rule.

With the ever-growing barrage of rhetoric over just how, when, and if, AI will kill us all, the conversation also lends itself to, do we believe it will be AI that kills us, or a bad actor using AI? If I showed you a picture of East Asia at night from space and pointed out that you can’t see North Korea for the lack of available electricity, (It’s 99% blacked out, and only Pyongyang shows a small cluster of light) would you think for a minute that they would have the tech savvy, and high end software, or even hardware, necessary to steal $6.7 billion in crypto since 2017?

The Securities and Exchange Commission issued a proposed rule, “Regulation Crypto Assets,” 91 Fed. Reg. 54510, on August 21, 2026 (FRN). Comments are due by October 20, 2026. Comments should reference File Number S7-2026-27 and may be submitted through the SEC’s internet comment form