As close observers of the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) are aware, the Committee has the authority to recommend that the President of the United States block a transaction on...more
On July 26, 2021, the Committee on Foreign Investment in the United States (CFIUS) released its unclassified Annual Report to Congress for the 2020 calendar year. The Annual Report provides statistics and insights into the...more
On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...more
4/20/2021
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Blocked Person ,
CBW Act ,
Cybersecurity ,
Defense Sector ,
Espionage ,
Executive Orders ,
Export Controls ,
Foreign Interference in US Elections ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
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Russia ,
Sanctions ,
SDN List ,
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Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts ,
Technology Sector ,
Ukraine ,
Vladimir Putin
Parties to investment transactions involving U.S. businesses engaged in “critical technologies” activities will soon be subject to modified requirements for mandatory filings to the Committee on Foreign Investment in the...more
9/18/2020
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Corporate Counsel ,
Critical Infrastructure Sectors ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
FIRRMA ,
Foreign Investment ,
ITAR ,
NAICS ,
National Security ,
U.S. Commerce Department ,
U.S. Treasury
On March 4, 2020, the U.S. Department of the Treasury (Treasury) issued a proposed rule to establish–for the first time–filing fees for parties submitting jointly voluntary notices to the Committee on Foreign Investment in...more
Global M&A made another strong showing in 2019, as stock markets, while at times bumpy, rose to new highs, private equity firms raised record funds, and companies searched for growth and ways to address technological and...more
The U.S. Department of the Treasury (Treasury) has released final regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA), expanding the jurisdiction of the Committee on Foreign Investment in...more
On December 13, 2019, the Department of Justice’s National Security Division (“NSD”) announced a revised policy to encourage voluntary self-disclosures (“VSDs”) of criminal violations of export control and sanctions laws. The...more
As it nears the end of the calendar and legislative year, Congress is preparing to take long-awaited action to kill Russia’s Nord Stream 2 and TurkStream natural gas pipeline projects – months before Nord Stream 2’s...more
On September 24, 2019, the U.S. Department of the Treasury ("Treasury") published in the United States Federal Register the proposed regulations developed by the United States Committee on Foreign Investment (CFIUS) to...more
This is the fourth in our multipart series of alerts addressing proposed regulations published in the Federal Register on September 24, 2019, for the Committee on Foreign Investment in the United States (CFIUS) to implement...more
On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced it was removing three Turkish government ministers and two Turkish government ministries from its list of Specially Designated...more
On October 14, President Trump issued an Executive order (“E.O.”) imposing sanctions on Turkey in response to Turkey’s military offensive in northern Syria. New E.O. 13894 authorizes the U.S. Departments of State and the...more
This is the third in our multipart series of alerts addressing proposed regulations published in the Federal Register on September 24, 2019, for the Committee on Foreign Investment in the United States (CFIUS) to implement...more
The U.S. Department of Commerce (“Commerce”) has added 28 Chinese organizations to the Bureau of Industry and Security (BIS) Entity List, a move that effectively cuts off these entities from directly or indirectly acquiring...more
After more than a year of anticipation, the U.S. Department of the Treasury (“Treasury”) has released proposed regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA). These proposed regulations...more
This is the second in our multipart series of alerts addressing proposed regulations published in the Federal Register on September 24, 2019, for the Committee on Foreign Investment in the United States (CFIUS) to implement...more
After more than a year of anticipation, the U.S. Department of the Treasury (“Treasury”) has released proposed regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA). These proposed regulations...more
As part of the 18th anniversary of the September 11 attacks earlier this month, the Trump Administration effectively declared the old adage that “one person’s terrorist is another person’s freedom fighter” does not apply with...more
Hot on the heels of the “Saturday Surprise,” the Trump Administration initiated “Monday Madness” earlier this week when the President issued new Executive Order (E.O.) 13884 blocking any property and interests in property of...more
8/9/2019
/ Blocked Entities ,
Blocked Person ,
CFIUS ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Humanitarian Assistance ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Trump Administration ,
Venezuela
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has a well-earned reputation in the sanctions bar for ruining weekends. The agency responsible for implementing and enforcing U.S. economic sanctions has...more
On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published its first-ever Framework for OFAC Compliance Commitments (“Framework”), detailing the essential components of a sanctions...more
Back in February, we told you about the Defending American Security from Kremlin Aggression Act, or “DASKA,” a bipartisan effort to impose new sanctions on Russia. Interest in action against the Kremlin has only increased...more
An Attempt to Limit the Strain on the Telecom Sector, but Broad Prohibition on Exports Remains -
The Department of Commerce Bureau of Industry and Security (BIS) has issued a 90-day temporary general licenseexempting a set...more
With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more