COGR, AAU, and APLU Submit Joint Comments on BIS Interim Final Rule (RIN 0694-AK11)

COGR, together with AAU and APLU, submitted joint comments to the Bureau of Industry and Security (BIS) on its interim final rule, which expands end-user controls to affiliates of certain entities. The associations highlight that the rule, as written, could create substantial and ambiguous compliance burdens for universities and potentially stifle legitimate international research collaborations. They recommend that BIS adopt clear and practicable due diligence standards, provide transparency and guidance on “red flag” triggers, implement safe-harbor protections for good-faith compliance, and offer transitional relief and training to support effective implementation.