After over a year of preview, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has finally published information on its most recent enforcement actions.
The actions were announced on...more
9/4/2024
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
Compliance ,
Corporate Counsel ,
Data Security ,
Divestment ,
Enforcement ,
Failure to Comply ,
Foreign Investment ,
National Security ,
National Security Agency (NSA) ,
Penalties ,
Transparency
The U.S. Department of Treasury (“Treasury”), which is Chair of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”), released a Notice of Proposed Rulemaking on April 11, 2024 (“NPRM”) meant...more
On September 14, 2023, the U.S. Department of Treasury (“Treasury”) hosted its Second Annual CFIUS Conference (the “Conference”) regarding the Committee on Foreign Investment in the United States (“CFIUS” or the...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently announced two settlements that underscore OFAC’s continued emphasis on companies developing and implementing effective, risk-based...more
Speaking recently at a conference concerning the Committee on Foreign Investment in the United States (“CFIUS” or the Committee”) in Washington, D.C., senior CFIUS officials from the Department of Defense (“DOD”), the...more
5/10/2023
/ Biden Administration ,
CFIUS ,
Cybersecurity ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Enforcement ,
Executive Orders ,
FIRRMA ,
New Regulations ,
Penalties ,
U.S. Treasury
In 2022, the US, UK and EU all escalated their sanctions enforcement rhetoric. For example, senior US enforcement officials went so far as to describe sanctions as “the new FCPA” (referring to the US. Foreign Corrupt...more
2/17/2023
/ Civil Sanctions ,
Compliance ,
Economic Sanctions ,
Enforcement ,
EU ,
Liability ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Russia ,
UK ,
Ukraine
Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine.
Actions have...more
12/19/2022
/ Asset Freeze ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
EU ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Good Faith ,
Imports ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
Safe Harbors ,
SDN List ,
U.S. Treasury ,
UK ,
Ukraine
On June 30, 2014, BNP Paribas SA (“BNPP”), the largest bank in France, pled guilty to conspiring to violate U.S. sanctions laws and agreed to pay a total of nearly $8.9 billion in criminal forfeiture and penalties to the U.S....more
Despite Russia’s reputation for corruption, the anti-bribery climate in Russia is evolving. A recent flurry of anti-bribery legislation, as well as Russia’s ratification of the OECD Convention on Combating Bribery of Foreign...more