On 24 March 2025, the White House issued an Executive Order threatening to impose a 25% tariff on all goods imported into the United States from any country that imports Venezuelan oil directly or indirectly through third...more
On 21 February 2025, President Donald J. Trump signaled his administration’s approach to foreign investment policy with a presidential memorandum, “America First Investment Policy” (The Policy). Among the most significant...more
Here are 10 ways to avoid, mitigate, or delay the costs of new tariffs that President-elect Trump has promised for countries like China, Canada, and Mexico: Confirming country of origin: Determine whether tariffs apply by...more
1/16/2025
/ Canada ,
China ,
Corporate Counsel ,
Imports ,
Mexico ,
National Security ,
Section 232 ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Relations
On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of new sanctions targeting Russia’s energy sector. In an effort to curtail Russia’s oil revenue and ability...more
On 21 June 2024, the Office of Investment Security of the US Department of the Treasury (Treasury) issued proposed regulations to implement President Biden’s August 2023 Executive Order on Addressing United States Investments...more
6/27/2024
/ CFIUS ,
China ,
Civil Monetary Penalty ,
Critical Infrastructure Sectors ,
Executive Orders ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
Investment ,
National Security ,
Prohibited Transactions ,
Proposed Regulation ,
Supply Chain ,
U.S. Treasury
On 17 October 2023, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued two new Interim Final Rules (collectively, the Updated Rule) that significantly revise and expand controls under the US Export...more
10/30/2023
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
End-Users ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Interim Final Rules (IFR) ,
National Security ,
Semiconductors ,
U.S. Commerce Department
Earlier this month, the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) took two noteworthy actions that underscore the Committee’s powerful role in reviewing foreign direct investment and...more
On January 13, 2020, the U.S. Department of the Treasury (“Treasury”) published two final rules (“Final Rules,” found here and here) that implement most of the remaining provisions of the Foreign Investment Risk Review...more
On November 27, 2019, the Department of Commerce (“Commerce”) issued a proposed rule implementing Executive Order (“EO”) 13873, “Securing the Information and Communications Technology and Services Supply Chain,” issued on May...more
On September 24, 2019, the U.S. Department of the Treasury (“Treasury”) published two proposed rules (together, the “Proposed Rules”) to implement the remaining provisions of the Foreign Investment Risk Review Modernization...more
Two major actions by the Committee on Foreign Investment in the United States (“CFIUS”) have recently come to light that underscore the significant risks of investments in U.S. businesses that have large volumes of sensitive...more