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CFIUS Non-Notified Transaction Enforcement: Cooley’s Five-Year Lookback

March 2025 marked the fifth anniversary of the Committee on Foreign Investment in the United States (CFIUS) initiative to “formalize and centralize” within the Department of the Treasury an enforcement function to identify...more

US Outbound Investment Enforcement Is Now Live

Despite uncertainty amid talks of reforming the Outbound Investment Security Program (OISP), the US Department of the Treasury is already actively pursuing enforcement actions against transaction parties that may have...more

Assessing the Impact of the Outbound Investment Security Program on Debt Transactions

On January 2, 2025, the US Department of the Treasury implemented the new Outbound Investment Security Program (OISP), which prohibits or imposes notification requirements on certain investments by US persons in persons that...more

Outbound Investment Security Program: Final Rule

On October 28, 2024, the US Department of the Treasury issued final regulations implementing the Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of...more

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