On July 17, 2020, the US Department of Commerce, Bureau of Industry & Security (“BIS”), published a Notice of Inquiry (“Notice”)1 seeking public comments on potential changes to items controlled for crime control and detection (“CC”) reasons under the Export Administration Regulations (“EAR”)2 and the related licensing requirements. Among other possible changes, BIS may expand export licensing requirements for devices, software and technology related to facial recognition and biometric systems. The Notice has significant implications for businesses engaged in industries related to biometrics, as it involves emerging and advanced technologies having important commercial applications. Comments in response to the Notice are due by September 15, 2020.

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