Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more
3/7/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Supply Chain
What Has President Trump Announced?
On February 10, 2025, President Trump signed proclamations titled Adjusting Imports of Steel Into the United States and Adjusting Imports of Aluminum into the United States. The...more
On February 10 President Trump issued an Executive Order, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security, signaling a shift in U.S. enforcement priorities regarding...more
During his campaign, President Trump often stated that he would be implementing an “America First” international trade policy, which he said explicitly would include higher tariffs, potentially on imports from the entire...more
1/24/2025
/ America First Trade Policy ,
China ,
Corporate Counsel ,
Export Controls ,
Free Trade Agreements ,
Imports ,
National Security ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Unfair or Deceptive Trade Practices ,
United States-Mexico-Canada Agreement (USMCA) ,
USTR
As an accompaniment to our biweekly series on “What Every Multinational Company Should Know About” various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that...more
1/24/2025
/ Compliance ,
Customs ,
Customs and Border Protection ,
Cybersecurity ,
Forced Labor ,
Human Rights ,
International Trade ,
Labor Regulations ,
National Security ,
Risk Management ,
Supply Chain
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has promulgated a Final Rule prohibiting the import and sale of connected vehicles and related components linked to the People’s Republic of China (PRC)...more
1/16/2025
/ Automation Systems ,
Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Cybersecurity ,
Final Rules ,
National Security ,
OEM ,
Regulatory Requirements ,
Russia ,
Supply Chain ,
Transparency ,
U.S. Commerce Department
CFIUS is an interagency committee that evaluates the national security implications of foreign investments on the U.S. economy and infrastructure. CFIUS possesses statutory authority to “make an investigation to determine the...more
Recent developments include fair warning from the Department of Justice that national security concerns can invade even ordinary business activities, a reminder that the False Claims Act increasingly is being used as a weapon...more
6/22/2023
/ Antitrust Division ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
False Claims Act (FCA) ,
International Trade ,
National Security ,
U.S. Commerce Department ,
Voluntary Disclosure
In 2022, automotive suppliers face many of the same issues that have bedeviled the industry throughout 2021, as well as a host of all-new challenges. Unfortunately, as with many aspects of pre-pandemic life, the relative...more
3/17/2022
/ Automotive Industry ,
Biden Administration ,
Coronavirus/COVID-19 ,
Corruption ,
Department of Justice (DOJ) ,
Department of Transportation (DOT) ,
Electric Vehicles ,
Federal Trade Commission (FTC) ,
Final Rules ,
Foreign Corrupt Practices Act (FCPA) ,
Hart-Scott-Rodino Act ,
IMMEX ,
Infrastructure Investment and Jobs Act (IIJA) ,
Mexico ,
Motor Vehicles ,
National Security ,
NHTSA ,
Notice of Proposed Rulemaking (NOPR) ,
OEM ,
Office of Foreign Assets Control (OFAC) ,
OMB ,
Supply Chain ,
Supply Shortages ,
U.S. Treasury ,
Vertical Mergers
If private equity and other investors were not aware of the power of the secretive Committee on Foreign Investment in the United States (CFIUS, or the Committee), its decision to reach out and quash the potential...more
4/18/2018
/ Acquisitions ,
Blocked Mergers ,
Broadcom ,
CFIUS ,
China ,
FINSA ,
FIRRMA ,
Foreign Investment ,
Hostile Takeover ,
Infrastructure ,
Intellectual Property Protection ,
ITAR ,
Mergers ,
National Security ,
Qualcomm ,
Section 301 ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trump Administration
On March 23rd, automotive companies that rely on imported steel and aluminum were confronted with new special tariffs of 25 percent on all imports of steel and tariffs of ten percent on all imports of aluminum, with temporary...more
4/6/2018
/ Automotive Industry ,
Bureau of Industry and Security (BIS) ,
Exclusions ,
Imports ,
Manufacturers ,
National Security ,
Section 232 ,
Steel Industry ,
Tariffs ,
Trade Policy ,
Trump Administration
On March 23, automotive companies that rely on imported steel and aluminum were confronted with new special tariffs of 25 percent on all imports of steel and tariffs of 10 percent on all imports of aluminum, with temporary...more
4/4/2018
/ Automotive Industry ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Exclusions ,
Imports ,
Manufacturers ,
NAFTA ,
National Security ,
Section 232 ,
Steel Industry ,
Tariffs ,
Trade Policy ,
Trump Administration ,
U.S. Commerce Department ,
WTO
On March 23rd, steel and aluminum users were confronted with new special tariffs of 25 percent on all imports of steel and tariffs of ten percent on all imports of aluminum, with temporary exclusions for Argentina, Australia,...more
3/26/2018
/ Automotive Industry ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Exclusions ,
Imports ,
Manufacturers ,
NAFTA ,
National Security ,
Section 232 ,
Steel Industry ,
Tariffs ,
Trade Policy ,
Trump Administration ,
U.S. Commerce Department ,
WTO
An open question coming into 2017 was whether the aggressive enforcement posture that had characterized the Obama and Bush administrations would continue under the Trump administration. Any questions were answered with the...more
3/19/2018
/ Anti-Bribery ,
Anti-Corruption ,
Automotive Industry ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement Actions ,
Exports ,
Extraterritoriality Rules ,
Foreign Corrupt Practices Act (FCPA) ,
Joint Comprehensive Plan of Action (JCPOA) ,
Manufacturers ,
Multinationals ,
NAFTA ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Tariffs ,
Trade Policy ,
Trump Administration
The international trade front has had some important developments over the last few weeks that will likely have significant impacts on the construction of domestic wind, solar, biomass and other types of renewable energy...more
3/12/2018
/ China ,
Countervailing Duties ,
Department of Defense (DOD) ,
Imports ,
NAFTA ,
National Security ,
Section 232 ,
Steel Industry ,
Tariffs ,
Trade Policy ,
Trump Administration ,
WTO
On March 1st, the automotive sector that consume steel and aluminum were confronted with a potentially large tariff rate increase. Despite intense lobbying by automotive companies, President Trump announced that the U.S....more
Companies that import steel or aluminum saw the detonation of a major international trade bomb on March 1st. President Trump announced that the U.S. Government would invoke the seldom-used section 232 national security...more
3/6/2018
/ Anti-Dumping Duty ,
Automotive Industry ,
CFIUS ,
Countervailing Duties ,
Department of Defense (DOD) ,
Imports ,
NAFTA ,
National Security ,
Section 232 ,
Steel Industry ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trade Policy ,
Trump Administration ,
U.S. Commerce Department ,
WTO
As shown by the recent announcement by the Trump Administration of a Section 232(b) national security review of steel imports, (a type of investigation that has not been used since 2001), there are a number of ways in which...more
5/5/2017
/ Antitrust Violations ,
Customs and Border Protection ,
False Advertising ,
Imports ,
Intellectual Property Protection ,
International Trade Commission (ITC) ,
Lanham Act ,
National Security ,
Price-Fixing ,
Section 232 ,
Section 337 ,
Steel Industry ,
Tariff Act of 1930 ,
Trade Remedies ,
Trade Secrets ,
Trump Administration ,
Unfair Competition ,
Unfair or Deceptive Trade Practices
Since President Trump’s inauguration, cybersecurity has been in the news almost daily – often on the front page. The U.S. Government is facing a wide array of challenges in cybersecurity, impacting both domestic and foreign...more
5/2/2017
/ Chief Information Security Officer (CISO) ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Cyber Attacks ,
Cybersecurity ,
Data Privacy ,
EU-US Privacy Shield ,
Federal Trade Commission (FTC) ,
National Security ,
Obama Administration ,
Popular ,
Public Private Partnerships (P3s) ,
Securities and Exchange Commission (SEC) ,
Trump Administration
One of the themes of the Trump campaign was the need for enhanced national security. Although the Committee of Foreign Investment in the United States (CFIUS) is not mentioned in Mr. Trump’s 100-day plan, it is highly likely...more
1/25/2017
/ Acquisitions ,
CFIUS ,
China ,
Corporate Counsel ,
Cross-Border Transactions ,
Foreign Investment ,
Mergers ,
National Security ,
Popular ,
Trump Administration ,
USTR ,
Young Lawyers