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First Quarter Foreign Direct Investment Updates

On February 21, 2025, the Trump administration published its “America First Investment Policy” memorandum. Among other items, the Policy calls for the United States to restrict China-affiliated persons from investing in...more

Semiconductor Tariff Exclusions & New Section 232 Investigations

This article provides an overview of the most recent tariff updates affecting businesses operating within the semiconductor, pharmaceutical, and critical mineral industries. Below we outline recent tariff exclusions for...more

America First Investment Policy Restricts Adversaries and Welcomes Investment from Allies

On February 21, 2025, President Trump issued a memorandum titled "America First Investment Policy" (the “Policy”), outlining new measures to shape U.S. investment policy. Though the Policy makes it clear that the United...more

DOJ Memoranda Impact FCPA, FARA, and Other National Security Enforcement Priorities

President Trump’s pick for Attorney General, Pam Bondi, took quick action upon her swearing in on February 5, 2025, to make changes within the Department of Justice (“DOJ”) via the issuance of fourteen separate memorandum...more

DOJ’s Increasing Role in the Enforcement of U.S. Trade Laws

Multiple federal agencies are charged with enforcing U.S. international trade and national security laws. These agencies include the Department of Commerce Bureau of Industry and Security (BIS) and the Department of State...more

InsightsCommerce Imposes Sweeping New Rule Restricting Exports of AI Chips

On January 13, 2025, the Department of Commerce Bureau of Industry and Security (BIS) announced new rules restricting the export of advanced artificial intelligence (AI) chips and certain closed AI model weights in an...more

U.S. Issues Unprecedented Order Restricting Investment in China

Senator Cornyn made the above statement on the Senate floor on November 14, 2023, while advocating for his colleagues to pass the Outbound Investment Transparency Act as part of the 2024 National Defense Authorization Act...more

New Rules Further Restrict China’s Access to Semiconductor Technology

On December 2, 2024, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) issued two new rules further restricting China’s capability to produce advanced semiconductors. One final rule (the “Entity List...more

The Mergers & Acquisitions Review: US Trade Compliance Due Diligence 2024

In addition to a myriad of issues to consider during M&A transactions, parties should conduct due diligence related to US trade regulations and the often-related foreign investment regulations that arise in the context of an...more

The Corporate Transparency Act: Treasury’s New Back Door for Finding CFIUS Non-Notified Transactions

Much has been written about the Corporate Transparency Act (“CTA”), which was enacted on January 1, 2021, and went into effect on January 1, 2024. Briefly, the CTA requires “reporting companies” to disclose beneficial...more

Amid TikTok Tensions, CFIUS Signals Increased Enforcement and Other Updates

MENU InsightsAmid TikTok Tensions, CFIUS Signals Increased Enforcement and Other UpdatesBy: Derrick Kyle, Senior AssociateDate: 04/25/2023As TikTok CEO Shou Zi Chew was facing (often contentious) questions from members of...more

Federal Investigations within the Department of Homeland Security [Video]

In the aftermath of 9/11, the U.S. Government created the Department of Homeland Security to carry out a broad range of national security functions. Today, DHS is widely known for overseeing both Immigrations and Customs...more

Congress Contemplates Committee to Review Outbound Investment

On February 4, 2022, the House of Representatives passed the National Critical Capabilities Defense Act of 2021 (“NCCDA”) as part of the much larger America Creating Opportunities for Manufacturing, Pre-Eminence in...more

When CFIUS Mitigation Agreements and FOCI Reviews Overlap: A Critical Balancing Act

On June 9, 2021, Momentus Inc., a U.S. commercial space company offering in-space transportation and infrastructure services, as a condition to its acquisition by a foreign-owned company, entered into a National Security...more

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