Norwegian Law Firm Warns of Compliance Risks From New Tech Controls

Companies affected by Norway’s recently announced export controls on emerging technologies should “act promptly” to make sure their exports don’t raise any legal or reputational risks, including by updating internal compliance programs, training employees on new licensing requirements and correctly classifying their goods and technology, the law firm Wikborg Rein said in an October client alert. The firm also said companies should review their current business dealings to identify any transactions that will require a license after the new controls take effect Nov. 1.

Norway announced the new controls Oct. 3, following similar moves by the U.S. and other member states of the Wassenaar Arrangement, which have sought to introduce controls on their own because Russia remains a Wassenaar member and can veto new proposals (see 2410030050).

Wikborg Rein said Norway’s new controls place restrictions on emerging technologies related to materials processing, electronics and computers. The firm specifically pointed to additive manufacturing equipment, also known as 3D printing technology, which will face new license requirements, along with “dry etching equipment” and other semiconductor manufacturing components.

Norway is also controlling certain advanced materials, including “enriched silicon and germanium with purity levels essential for semiconductor applications”; certain high-performance electronics with “certain high data transfer rates and processing performance; quantum computing technologies, including systems “supporting a certain number of fully controlled and connected physical qubits with low error rates”; and “software and technology for reverse engineering.”