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BIS Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

BIS Clarifies Notification and Licensing Requirements for Updated Semiconductor, Advanced Computing Export Controls

On December 29, 2023, the Commerce Department’s Bureau of Industry and Security (BIS) issued Frequently Asked Questions (FAQs) concerning the agency’s recently updated semiconductor and advanced computing export controls. In...more

White House Issues Executive Order on Outbound Investment Screening

On August 9, 2023, the White House issued Executive Order 14105 (“EO”) to address the national security threat posed by outbound investment in certain countries of concern that seek to develop and exploit sensitive or...more

CFIUS Issues New Enforcement and Penalty Guidance

On October 20, the Committee on Foreign Investment in the United States (CFIUS or the Committee) issued a press release laying out new guidance to provide clarity about how the Committee assesses violations of the laws and...more

Biden Administration Issues Executive Order Defining Additional National Security Considerations for CFIUS

On September 15, President Biden signed an Executive Order (EO) with the first ever formal Presidential direction to the Committee on Foreign Investment in the United States (CFIUS or the Committee). The EO emphasizes the...more

How New CFIUS Rules on Critical Technology Affect CFIUS Filing Strategy

The Department of Treasury’s office that administers reviews of foreign investments in U.S. companies is changing how it identifies critical technology businesses and related technologies that require mandatory review during...more

CFIUS to Cover More Foreign Investments in U.S. Companies

Companies outside the U.S. contemplating purchases of U.S. business (and potential U.S. acquisition targets) are continuing to parse the Department of the Treasury’s two proposed regulations continuing implementation of the...more

Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA)

After months of negotiation, Congress recently passed, and the president is expected to sign, the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”).[1] FIRRMA updates the national security review of inbound...more

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