Key considerations and practical steps for data center companies, cloud services companies, and those operating on the cloud....more
3/23/2026
/ Bureau of Industry and Security (BIS) ,
Cloud Computing ,
Cloud Service Providers (CSPs) ,
Compliance ,
Data Centers ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
International Trade ,
National Security ,
New Legislation ,
Proposed Legislation ,
U.S. Commerce Department
On February 6, 2026, the US Department of the Treasury (Treasury), as chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Request for Information (RFI) seeking public feedback on how CFIUS can...more
2/17/2026
/ Administrative Review ,
CFIUS ,
Comment Period ,
Cross-Border Transactions ,
Due Diligence ,
Foreign Investment ,
Investors ,
National Security ,
Regulatory Reform ,
Request For Information ,
Trump Administration ,
U.S. Treasury
This measure significantly expands the scope of Entity List and Military End-User List restrictions, imposing heightened diligence obligations and complicating EAR compliance....more
10/6/2025
/ Bureau of Industry and Security (BIS) ,
Due Diligence ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Foreign Entities ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
U.S. Commerce Department
On August 6, 2025, the Committee on Foreign Investment in the United States (CFIUS) released the public version of its Annual Report to Congress for Calendar Year 2024 (the Report), which highlights CFIUS’ priorities,...more
8/12/2025
/ Annual Reports ,
CFIUS ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Direct Investment ,
Foreign Investment ,
Investors ,
National Security ,
Private Equity ,
Risk Mitigation ,
U.S. Treasury
General License 25 effectively suspends OFAC sanctions targeting Syria. Stringent US export control restrictions on exports and reexports to Syria remain....more
5/28/2025
/ Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Syria ,
Trump Administration ,
U.S. Treasury ,
UK
The report shows a decline in filings, new mitigation measures and conditions, and continued emphasis on monitoring and enforcement.
On July 23, 2024, the Committee on Foreign Investment in the United States (CFIUS)...more
The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US.
On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more
7/2/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Controlled Foreign Corporations ,
Covered Entities ,
Executive Orders ,
Foreign Investment ,
Foreign Policy ,
International Emergency Economic Powers Act (IEEPA) ,
Military End Use ,
National Security ,
Outbound Transactions ,
Popular ,
Prohibited Transactions ,
Proposed Regulation ,
Public Comment ,
SDN List ,
Technology Sector ,
U.S. Commerce Department ,
U.S. Treasury
The proposal signals a continued effort to expand CFIUS’s enforcement scope and update penalties.
On April 11, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed Rulemaking (the Proposed Rule)...more
The new measures bar the import of iron or steel products processed in countries other than Russia but incorporating Russian-origin iron or steel components. The measures form part of a series of significant sanctions updates...more
The new measures build on sweeping restrictions that the United States introduced in October 2022.
On October 17, 2023 — just over a year after introducing extensive regulations aimed at restricting parties in China from...more
10/31/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Defense Sector ,
Entity List ,
Export Controls ,
Exports ,
Military End Use ,
National Security ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
After publicly signaling support for an outbound investment screening mechanism in July 2022, the Biden Administration has issued a long-anticipated Executive Order to address certain investments by US persons in “countries...more
8/16/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Comment Period ,
Executive Orders ,
Foreign Investment ,
Hong Kong ,
International Emergency Economic Powers Act (IEEPA) ,
Macau ,
National Security ,
Outbound Acquisitions ,
Outbound Transactions ,
Prohibited Transactions ,
U.S. Treasury
The Report shows that CFIUS reviewed a record number of filings in 2022 and also required more mitigation as a condition of clearance.
On July 31, 2023, the Committee on Foreign Investment in the United States (CFIUS)...more
8/8/2023
/ CFIUS ,
China ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Enforcement ,
Foreign Acquisitions ,
Foreign Investment ,
Life Sciences ,
National Security ,
Singapore ,
United Arab Emirates (UAE)
New measures expand existing sanctions and export controls, including by restricting medical item exports and targeting Russia’s architecture and engineering sectors.
This Client Alert is published in the context of...more
The recent developments signal a renewed vigor to protect US national security.
This Client Alert highlights the following recent developments relating to national security investment reviews conducted by the Committee on...more