The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more
2/24/2025
/ Compliance ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Department of Justice (DOJ) ,
Due Diligence ,
Executive Orders ,
Final Rules ,
Food and Drug Administration (FDA) ,
Foreign Entities ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
National Security ,
NIST ,
Personal Data ,
Sensitive Personal Information
The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more
2/20/2025
/ Compliance ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Department of Justice (DOJ) ,
Executive Orders ,
Final Rules ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
National Security ,
Regulatory Requirements ,
Sensitive Personal Information
On April 24, 2024, President Biden signed into law H.R. 815, a national security and foreign aid package which includes the “Protecting Americans’ Data from Foreign Adversaries Act of 2024” (“PADFA”). The Act establishes new...more
On March 1, 2024, the Department of Commerce (Commerce), Bureau of Industry and Security (BIS), through its Office of Information and Communication Technology and Services (ICTS), released an advanced notice of proposed...more
3/4/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
China ,
Executive Orders ,
Foreign Adversaries ,
National Security ,
Satellites ,
Software ,
Supply Chain ,
Telecommunications ,
U.S. Commerce Department
On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a proposed rule (the Proposed Rule) that would impose significant know-your-customer (KYC), monitoring and reporting obligations...more
2/2/2024
/ Biden Administration ,
Cloud Service Providers (CSPs) ,
Enforcement ,
Executive Orders ,
Foreign Jurisdictions ,
Infrastructure ,
Know Your Customers ,
Penalties ,
Proposed Rules ,
Reporting Requirements ,
Verification Requirements
Key Points -
On August 9, 2023, President Biden issued a long-anticipated Executive Order on outbound investment aimed at addressing concerns related to China’s advancement in sensitive technologies critical for military,...more
The U.S. government continues to move closer to establishing a regulatory program related to outbound investment—and potentially a range of other transactions—in sensitive technology sectors involving China, Russia and other...more
Key Points -
EO 14083 provides updated guidance to CFIUS regarding its consideration of U.S. national security risk factors and is aimed at confronting evolving and emerging threats to U.S. technological leadership, U.S....more
Key Points -
On November 26, 2021, the U.S. Department of Commerce issued a notice of proposed rulemaking related to “connected software applications” (“apps”) that aims to expressly incorporate transactions involving...more
Key Points -
On June 9, President Biden signed an executive order (“EO”) revoking a series of Trump-era EOs targeting specific Chinese “connected software applications” (“apps”), including TikTok and WeChat.
The EO calls...more
6/23/2021
/ Biden Administration ,
Critical Infrastructure Sectors ,
Cybersecurity ,
Department of Justice (DOJ) ,
Executive Orders ,
Foreign Adversaries ,
Mobile Apps ,
National Security ,
Personal Data ,
Popular ,
Supply Chain
On June 3, 2021, President Biden issued Executive Order 14032 (Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China) (“CMIC EO”) that modifies the Trump-era...more
The U.S. government has recently imposed controls pertaining to “Communist Chinese Military Companies” (CCMCs or “1237 entities”); Chinese “Military End Users” (MEUs); and Chinese “Military-Intelligence End Users” (MIEUs)....more
Key Points
- On November 12, 2020, President Trump issued a new EO prohibiting U.S. persons from engaging in transactions in publicly traded securities of certain CCMCs, or any securities that are derivative of, or are...more
1/4/2021
/ China ,
Department of Defense (DOD) ,
Derivatives ,
Executive Orders ,
Financial Instruments ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Publicly-Traded Companies ,
SDN List ,
Trade Relations ,
Trump Administration ,
US Trade Policies
- On July 8, 2020, the Department of Energy (DOE) published a Request for Information (RFI) concerning Executive Order 13920, “Securing the United States Bulk-Power System” (the “E.O.”). The E.O. authorizes the DOE to block...more
7/13/2020
/ Comment Period ,
Cybersecurity ,
Department of Energy (DOE) ,
Electricity ,
Energy Projects ,
Energy Sector ,
Executive Orders ,
Foreign Adversaries ,
Request For Information ,
Rulemaking Process ,
Supply Chain
- On May 1, 2020, President Trump issued an Executive Order (E.O.) aimed at curtailing the use of foreign-sourced electric equipment installed on the U.S. “bulk-power system,” which is commonly understood to mean the U.S....more
On April 4, the White House released an Executive Order establishing the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (the “Committee”) to assess foreign...more
IN THIS ISSUE
• Anticorruption Developments
• Export Control Sanctions and Customs Enforcement
• Export Control and Sanctions Developments
• Global Investigations Resources
• Writing and Speaking...more
2/26/2020
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Civil Monetary Penalty ,
Criminal Conspiracy ,
Criminal Convictions ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Due Process ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
Fifth Amendment ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Guilty Pleas ,
Imports ,
Indictments ,
ITAR ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Red Notices ,
Sanction Violations ,
Sanctions ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Smuggling ,
Trump Administration ,
U.S. Treasury ,
Whistleblowers
Key Points
- On November 26, 2019, the U.S. Department of Commerce (“Commerce”) issued a proposed rule to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more
12/4/2019
/ CFIUS ,
Executive Orders ,
Foreign Acquisitions ,
Foreign Adversaries ,
Foreign Investment ,
Information and Communication Technology (ICT) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Proposed Regulation ,
Proposed Rules ,
Public Comment ,
Supply Chain ,
Trump Administration ,
U.S. Commerce Department
ANTICORRUPTION DEVELOPMENTS -
Telecommunications Company Fined $12 Million for FCPA Violations -
On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more
9/9/2019
/ Anti-Corruption ,
Appeals ,
Bribery ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Executive Orders ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Narcotics Kingpin Designation Act ,
General Licenses ,
Guilty Pleas ,
Huawei ,
Indictments ,
Internal Investigations ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Manufacturers ,
Medical Devices ,
Money Laundering ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Plea Agreements ,
Settlement ,
SFO ,
Smuggling ,
Suspensions & Debarments ,
Tariffs ,
Tax Evasion ,
Technology Sector ,
Telecommunications ,
Trump Administration ,
World Bank
• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List.
• As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more
2/6/2019
/ Blocked Person ,
Bonds ,
Capital Markets ,
Debt-Equity ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Securities Transactions ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
ANTICORRUPTION DEVELOPMENTS -
Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations -
On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more
10/2/2018
/ Anti-Corruption ,
Arms Export Control Act ,
Books & Records ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
CEOs ,
Civil Monetary Penalty ,
Comment Period ,
Consent Order ,
Corporate Fines ,
Country of Origin ,
Criminal Conspiracy ,
Criminal Prosecution ,
Customs ,
Defense Contracts ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Emerging Growth Companies ,
Energy Sector ,
Enforcement Actions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Control Reform (ECR) ,
Export Controls ,
Exports ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Interference in US Elections ,
General Licenses ,
Guilty Pleas ,
Indictments ,
Investigations ,
ITSR ,
List of Specified Persons (LSP) ,
Manufacturers ,
Mining ,
Money Laundering ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Pharmaceutical Industry ,
Public Comment ,
Real Estate Brokers ,
Recordkeeping Requirements ,
Remand ,
Reporting Requirements ,
Retailers ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
SFO ,
Testimony ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
Wire Fraud
ANTICORRUPTION DEVELOPMENTS -
$34 Million SEC Settlement for Legg Mason -
On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
9/6/2018
/ 3-D Technology ,
Anti-Corruption ,
Appeals ,
Berry Amendment ,
Bribery ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Civil Monetary Penalty ,
Corruption ,
Criminal Conspiracy ,
Criminal Penalties ,
Criminal Prosecution ,
Critical Infrastructure Sectors ,
Customs and Border Protection ,
Declination ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Embezzlement ,
Enforcement Actions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Filing Requirements ,
FIRRMA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Foreign Policy ,
Former Employee ,
General Licenses ,
Guilty Pleas ,
Immigration and Customs Enforcement (ICE) ,
Imports ,
Insurance Contracts ,
Internal Investigations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Jurisdiction ,
Licensing Rules ,
Money Laundering ,
National Security ,
NDAA ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Personal Data ,
Preliminary Injunctions ,
Probationary Period ,
Racketeering ,
Sanction Violations ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
SFO ,
Suspensions & Debarments ,
The Wassenaar Arrangement ,
Trade Agreements Act ,
Trump Administration ,
Wire Fraud ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
SEC Proposes Amendments to Whistleblower Award Program -
On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
7/11/2018
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Cybersecurity ,
Department of Justice (DOJ) ,
Director Nominations ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
General Licenses ,
Hiring & Firing ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Proposed Amendments ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Telecommunications ,
U.S. Commerce Department ,
UK ,
Whistleblower Awards ,
Wire Fraud ,
ZTE
ANTICORRUPTION DEVELOPMENTS -
SEC Proposes Amendments to Whistleblower Award Program -
On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
7/11/2018
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Cybersecurity ,
Department of Justice (DOJ) ,
Director Nominations ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
General Licenses ,
Hiring & Firing ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Proposed Amendments ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Telecommunications ,
U.S. Commerce Department ,
UK ,
Whistleblower Awards ,
Wire Fraud ,
ZTE
ANTICORRUPTION DEVELOPMENTS -
SEC Proposes Amendments to Whistleblower Award Program -
On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
7/11/2018
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Cybersecurity ,
Department of Justice (DOJ) ,
Director Nominations ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
General Licenses ,
Hiring & Firing ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Proposed Amendments ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Telecommunications ,
U.S. Commerce Department ,
UK ,
Whistleblower Awards ,
Wire Fraud ,
ZTE