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New Filing Fees For CFIUS Notices Enter Into Effect

Beginning on May 1, 2020, the Committee on Foreign Investment in the United States (CFIUS) will require a fee for any joint voluntary notice of a “covered transaction” or “covered real estate transaction.” This requirement...more

New Export Control Rules Confront Integration of Civilian and Military Technology Development in China, Russia, and Venezuela

On April 28, 2020, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published two final rules that will eliminate the license exception for civil end users (CIV) in the People’s Republic of China, Russia,...more

Executive Order Establishes New Committee to Review Foreign Investment in Communications Companies

TAKEAWAYS - Establishes deadlines for Committee to respond to FCC referrals - Invites Committee review of existing license holders - Resolution of long pending FCC proposed rulemaking expected - On April 4, 2020, the White...more

Mitigating CFIUS Risks for Foreign Lenders and Investors as Defaults and Uncertainty Mount in the COVID-19 World

TAKEAWAYS - A transfer of control of a borrower or its business to non-U.S. lenders who exercise remedies under financing documents could trigger CFIUS issues. CFIUS regulations adopted in February 2020 dramatically...more

CFIUS Update: Chinese Company Ordered to Divest Acquisition of U.S. Hotel Software Company

On March 6, 2020, President Trump issued an Executive Order (“EO”) instructing the Chinese company Beijing Shiji Information Technology Co., Ltd. (“Shiji”) to divest its acquisition of StayNTouch, Inc., a U.S.-based software...more

CFIUS Unveils Proposed Rule to Impose Filing Fees

On March 5, 2020, the U.S. Department of the Treasury issued a proposed rule establishing filing fees for parties submitting a voluntary notice to the Committee on Foreign Investment in the United States (CFIUS) for “covered...more

U.S. Expands Secondary Sanctions to Iran’s Industrial Sectors

On January 10, 2020, the United States imposed additional sanctions on Iran in the wake of recent tensions between the countries and the continuing broader ‘maximum pressure’ campaign on Iran. ...more

Compliance in 2020 – Key Takeaways from the ITAR Cloud Rule

On December 26, 2019, the Department of State published in the Federal Register an interim final rule amending the International Traffic in Arms Regulations (ITAR) to define “activities that are not exports, reexports,...more

Key Takeaways from CFIUS Final Rules Implementing FIRRMA

On January 13, 2020, the U.S. Department of the Treasury issued two final rules for the Committee on Foreign Investment in the United States (CFIUS) implementing the Foreign Investment Risk Review Modernization Act (FIRRMA),...more

District Court Overturns OFAC Fine Against Exxon

On December 31, 2019, the U.S. District Court for the Northern District of Texas overturned a $2 million fine imposed by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) against ExxonMobil Corp., and...more

Commerce Department Publishes Interim Final Rule Controlling Geospatial Imagery Software for Training AI

Companies anxiously awaiting the release of “emerging technology” export control rules now have an initial interim rule indicating how the Department of Commerce Bureau of Industry and Security (BIS) is likely to proceed....more

Commerce Department Issues New Proposed Rules on Telecommunications Supply Chain

On November 27, 2019, the US Commerce Department published a proposed rule implementing regulations following President Trump’s May 15, 2019 Executive Order 13783 (E.O.) on Securing the Information and Communications...more

U.S. Imposes Sanctions on Turkey – The Economic Fallout from Events in Syria

The U.S. Treasury Department has issued sanctions designations against Turkey’s Ministry of National Defense, Ministry of Energy and Natural Resources, and the Minsters of Defense, Energy and Interior pursuant to a new...more

New Proposed CFIUS Regulations Implementing FIRRMA

On September 17, 2019, the U.S. Department of Treasury issued two new proposed rules for the Committee on Foreign Investment in the United States (CFIUS) implementing the Foreign Investment Risk Review Modernization Act...more

Huawei Remains on the BIS Entity List but Senior Officials Suggest Export Licenses May Be Considered

As trade relations with China continue to evolve, Huawei Technologies Co., Ltd. (“Huawei”) and its foreign affiliates remain subject to broad U.S. export license requirements. ...more

Temporary General License Grants Huawei Limited Relief from Restrictions Imposed by Entity List Restrictions

On May 16, 2019, the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce added Huawei Technologies Co., Ltd. (Huawei) and sixty-eight of its non-U.S. affiliates to the Entity List, thereby prohibiting the...more

U.S. State Department Implements Title III of Helms-Burton Act Permitting Lawsuits Over Seized Properties in Cuba

On April 17, 2019, the Trump Administration announced that it will allow U.S. citizens whose property was seized by the Cuban Government after 1959 to sue foreign companies that “traffic” in their confiscated property....more

U.S. Commerce Department Releases Proposed Rulemaking for Export Controls on Emerging Technologies

On November 19, 2018, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a proposed rulemaking seeking public comment on criteria for identifying emerging technologies that are essential to U.S....more

OFAC Announces Sanctions Against Saudi Arabian Government Officials Pursuant to Global Magnitsky Act

On November 15, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 17 officials of the Government of Saudi Arabia for their purported role in the killing of journalist Jamal...more

Reinstatement of Iran Sanctions

On November 5, 2018, OFAC announced a large number of Iran-related sanctions designations and issued guidance on the end of the 180-day wind down period. ...more

CFIUS Announces Pilot Program Requiring Mandatory Declarations for Certain Non-Controlling Investments in Specified Critical...

The U.S. Department of the Treasury issued temporary regulations establishing a partial pilot program implementing two key changes to the jurisdiction and review of transactions by the Committee on Foreign Investment in the...more

State Department Imposes Chemical Weapons Sanctions on Russia

On August 8, 2018, the State Department announced that it had concluded that Russia was responsible for poisoning former double agent Sergei Skripal and his daughter Yulia using the nerve agent Novichok and that it had sent a...more

U.S. Formalizes Snap-Back of Sanctions with New Executive Order

On August 6, 2018, the Treasury Department’s Office of Foreign Assets Control (OFAC) released a new Executive Order to implement the previously announced re-imposition of U.S. sanctions for Iran. ...more

Congress Reaches Agreement on CFIUS Reform Legislation Broadening National Security Reviews and Addressing Emerging Technologies

House and Senate negotiators have agreed on proposed reforms to the Committee on Foreign Investment in the United States (CFIUS) foreign investment review process, which has been added as Title XVII of the FY2019 National...more

US Announces Withdrawal from JCPOA

Today, President Trump announced his intention to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA) and to impose the “highest level of economic sanctions” on Iran. The Office of Foreign Assets...more

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