Who I(aa)S Your Foreign Customer? Department of Commerce Proposes Foreign Customer Identification Requirements For U.S. IaaS Providers

Crowell & Moring – On January 29, 2024, the Department of Commerce released a proposed rule: Taking Additional Steps To Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities, which solicits comments regarding a proposed new set of regulations that would introduce significant new requirements for U.S.-based Infrastructure as a Service (IaaS) providers.