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Risk Mitigation U.S. Treasury

Akerman LLP

Treasury Proposes Enhancements to CFIUS Procedures, Penalties, and Enforcement Authority

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On April 11, 2024, the U.S. Department of the Treasury issued a Notice of Proposed Rulemaking (NPRM) proposing a new rule updating the mitigation and enforcement provisions of the regulations administered by the Committee on...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Holland & Knight LLP

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Dechert LLP

Keep Your Investors Close, but CFIUS Closer: Highlights from the CFIUS Annual Report and Other Developments in Washington

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On July 31, 2023, the U.S. Department of the Treasury (“Treasury”) published the Committee on Foreign Investment in the United States’ (“CFIUS” or the “Committee”) Annual Report to Congress on key activities, including...more

WilmerHale

US Government Reviews Record Foreign Investments for National Security Risk

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The Committee on Foreign Investment in the United States (CFIUS) reviewed a record number of transactions for national security risks in 2022: 440 covered transactions, up from 436 transactions in 2021, according to its...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: A Look at the Treasury Department’s April 2023 Report on Decentralized Finance or “DeFi”

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The report examines the vulnerabilities in DeFi, including potential gaps in the United States’ Bank Secrecy Act/anti-money laundering regulatory, supervisory, and enforcement regimes for DeFi. We first discuss how Treasury...more

HaystackID

CFIUS Compliance: Your Organization’s Growth and Investment Strategy May Be a Matter of National Security

HaystackID on

On Thanksgiving of 2014, I received an urgent call asking me to be in London in 24 hours. My assignment was to run the advanced forensics recovery team serving several foreign offices of Sony Pictures in the wake of a...more

Genova Burns LLC

DoorDash Hacker Incident Illustrates Third-Party Vendor Risks and Potential Vulnerabilities

Genova Burns LLC on

​​​​​​​Hackers have increasingly focused on third-party vendors as avenues to data held by associated businesses. On August 25, 2022, DoorDash announced that it had experienced a data breach which impacted the personal...more

Holland & Knight LLP

5 Key Takeaways from the 2022 Inaugural CFIUS Conference

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The interagency Committee on Foreign Investment in the United States (CFIUS or the Committee) hosted its 2022 Inaugural Conference on June 16, 2022. In its capacity as chair of CFIUS, the U.S. Department of the Treasury...more

BakerHostetler

Crypto Payment Initiatives Launch; Report Cites Evolving Crypto Views; G7, ECB, BIS Address Crypto Risks; DOJ, CFTC Target NFT...

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New Cryptocurrency Payments Systems, Tokens and Trade Associations Launch - A leading global cryptocurrency platform has reportedly announced a partnership with a global e-commerce platform that would allow e-commerce...more

Foley & Lardner LLP

POTUS Issues Executive Order Directing Study of Digital Assets

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On March 9, 2022, President Joe Biden signed the “Executive Order on Ensuring Responsible Development of Digital Assets” (the order), outlining his administration’s intention to begin a strategic review of potential...more

Latham & Watkins LLP

FSOC Issues Recommendations on Climate-Related Financial Risk

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A wide-ranging report encourages regulators to take a concerted approach to combat climate-related risks to the US financial system. On October 21, 2021, the Financial Stability Oversight Council (FSOC) published a...more

McDermott Will & Emery

Climate Change Regulation for US Insurers: September 2021 Update and Overview

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There are less than two months before world leaders meet in Glasgow for the UN-sponsored Climate Change summit known as the Conference of the Parties (COP 26). This summer, we have been inundated with dire reports about...more

White and Williams LLP

CFIUS 2020 Annual Report

White and Williams LLP on

In July 2021, the Committee on Foreign Investment in the United States (CFIUS) released its annual report to Congress. The report covers transactions filed with CFIUS for the calendar year 2020 and describes the CFIUS process...more

WilmerHale

Biden to Federal Government: Assess Financial Risk of Climate Change

WilmerHale on

On May 20, President Biden issued his Executive Order on Climate-Related Financial Risk (“Order”) which requires federal agencies to assess the potential impacts of climate change on public and private financial institutions...more

Morrison & Foerster LLP

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more

Goodwin

Financial Services Weekly Roundup: Treasury And SBA Codify Changes To PPP Flexibility Act

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In This Issue. The U.S. Department of the Treasury (Treasury) and the Small Business Administration (SBA) released an interim final rule to reflect changes made by H.R. 7010, the Paycheck Protection Program Flexibility Act,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Privacy & Cybersecurity Update - February 2020

In this month's edition, we examine the California attorney general's proposed modified regulations under the CCPA, the Treasury Department's new CFIUS regulations, and the SEC Office of Compliance Inspections and...more

Akin Gump Strauss Hauer & Feld LLP

OFAC’s New Framework for an Effective Sanctions Compliance Program Provides Important Risk Mitigation Advice

• The U.S. Department of the Treasury's Office of Foreign Assets Controls (OFAC) recently published guidance that describes the framework for an effective Sanctions Compliance Program (SCP). In its guidance, OFAC makes clear...more

Akin Gump Strauss Hauer & Feld LLP

Trump Administration Authorizes Lawsuits Against Companies that Deal in Property Confiscated by the Cuban Government and Tightens...

• Yesterday, May 2, the United States government allowed implementation of Title III of the Helms-Burton Act, for the first time since the law was enacted in 1996, to permit U.S. nationals to sue persons that “traffic” in...more

Dechert LLP

US Blockchain Enforcement and Litigation Update

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Over the past two years, prices for cryptocurrencies and other digital assets have experienced extreme gains and declines, while billions of dollars have been raised through Initial Coin Offerings (“ICOs”). In this dynamic...more

Troutman Pepper

Treasury Report Addresses Regulatory Approaches Affecting Investment Companies and Their Advisers

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As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

CFTC Comparability Determination on EU Margin Requirements and a Common Approach on Trading Venues - On October 13, 2017, the U.S. Commodity Futures Trading Commission ("CFTC") announced determinations by the CFTC and the...more

Eversheds Sutherland (US) LLP

NAIC Cybersecurity Forum Focuses on Escalating Threats and Best Remediation Practices

On September 10, the National Association of Insurance Commissioners (NAIC) co-sponsored a cybersecurity forum at the Center for Strategic and International Studies in Washington, DC. Featuring an impressive line-up of senior...more

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