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Second CHIPS Act Funding Opportunity Announcement Released: Up to $500 Million Available for Facilities for Semiconductor...

On September 29, 2023, the National Institute of Standards and Technology’s (NIST’s) CHIPS Program Office released a new funding opportunity announcement (FOA) for the construction, expansion, or modernization of facilities...more

"I See Dead Companies": CFIUS Aims an FAQ at the Venture Capital Model

One of the bigger surprises in the history of the Committee on Foreign Investment in the United States (CFIUS) began to unfold in May 2023, when CFIUS posted a new Q&A on the FAQ section of the CFIUS website. The FAQ...more

CHIPS Act First Funding Opportunity Announcement Expanded to Include Facilities for Wafers, Semiconductor Materials, and...

In February 2023, the National Institute of Standards and Technology’s (NIST’s) CHIPS Program Office published the first Funding Opportunity Announcement (FOA) under the CHIPS and Science Act. The original FOA was initially...more

Strings Attached: New Proposed Rules Outline National Security Guardrails for CHIPS Act Funding Recipients

On March 23, 2023, the National Institute of Standards and Technology (NIST) released a Notice of Proposed Rulemaking (proposed rule) that sets forth the national security guardrails for funding under the CHIPS and Science...more

CHIPS Program Office Releases Resources for Preparation of Applications

As described in our client alert earlier this month, the National Institute of Standards and Technology’s CHIPS Program Office published a Funding Opportunity Announcement (FOA) directed towards funding the construction,...more

CHIPS Act Funding Kicks Off: First Tranche of Funding Announced

On February 28, 2023, the National Institute of Standards and Technology’s (NIST’s) CHIPS Program Office published the first Funding Opportunity Announcement (FOA) under the CHIPS and Science Act. This initial FOA is directed...more

CFIUS Guidelines: Betwixt and Between

On October 20, 2022, the Committee on Foreign Investment in the United States (CFIUS or the Committee) issued its first-ever set of “Enforcement and Penalty Guidelines.” The Guidelines introduce for CFIUS participants a new...more

President Biden’s Executive Order on CFIUS Likely to Yield Incremental Tightening

On September 15, 2022, President Biden signed an Executive Order (EO) detailing certain national security risks that the Committee on Foreign Investment in the United States (CFIUS or the Committee) should consider when...more

A Tale of Two Filers: CFIUS Report Touts Efficiency, Also Indicates CFIUS Failed to Meet Statutory Deadlines for a Large...

This year's version of the annual Committee on Foreign Investment in the United States (CFIUS) report, released on August 2, 2022, and covering calendar year 2021, has a Dickensian quality. As usual, it's a dense work. But...more

CHIPS Act Basics for Semiconductor Companies: Early Answers on Finding Funding and Resulting Risks

On August 9, 2022, President Biden signed into law the CHIPS and Science Act of 2022 (the CHIPS Act), a significant investment in industrial policy that offers, among other things, funding for the development of facilities to...more

Proposed Legislation Seeks to Create "Reverse CFIUS": National Security Review of Outbound Activity Benefiting Entities or...

U.S. lawmakers have proposed requiring government approval for certain outbound investments, much as today's Committee on Foreign Investment in the United States regime requires a national security review of certain...more

BEIS Blocks First Transaction Under the UK’s National Security and Investment Act

On July 20, 2022, the Secretary of State for the Department for Business, Energy, and Industrial Strategy (BEIS) within the UK government published a final order blocking a proposed licensing arrangement between the...more

BEIS Publishes First Annual Report Regarding the UK's National Security and Investment Act

On June 16, 2022, the Department for Business, Energy, and Industrial Strategy (BEIS) published its first annual report regarding the National Security and Investment Act 2021 (the NSI Act). The report solely covers the...more

New Rules Will Require Beneficial Ownership Reporting to Federal Regulators by U.S. and Foreign Corporations, LLCs, and Other...

On December 8, 2021, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) published its proposed regulations on beneficial ownership information (BOI) reporting requirements. These FinCEN regulations will...more

The UK's National Security and Investment Act Now Fully in Force

The United Kingdom's National Security and Investment Act (the NSI Act) is now fully in force. First proposed in 2016, the NSI Act creates a stand-alone regime that authorizes the UK government to consider and address the...more

UK's National Security and Investment Act to Take Effect in January 2022

The United Kingdom's National Security and Investment Act (NSI Act) is scheduled to come fully into force on January 4, 2022. The NSI Act will create a new framework for the UK government to review so-called "trigger events,"...more

Companies That Procure IT Products or Services from China, Russia, and Certain Other "Adversary" Nations May Face New National...

Earlier this year, the Department of Commerce (Commerce) published an interim final rule to address the security of the U.S. supply chain for information technology (the Rule). The Rule, which has now taken effect as of March...more

A National Security Parting Gift to the New Administration: Additional Burdens for IT Supply Chains and Infrastructure as a...

On January 19, 2021, we saw the publication of both an interim final rule from the Department of Commerce (Commerce) to address the security of the U.S. supply chain for information technology (the Rule)1 and a new...more

CFIUS After FIRRMA Implementation: A Crash Course in Assessing and Navigating Risk

On October 15, 2020, the final rule implementing the baseline requirements of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) took effect. This final rule altered the mandatory filing rules of the...more

As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat

This past weekend saw a halt to the anticipated September 20 implementation of broad prohibitions published on September 18 by the U.S. Department of Commerce (Commerce) regarding TikTok and WeChat mobile applications. No...more

U.S. Department of Commerce Publishes Transactions with ByteDance and Tencent That Are Prohibited Due to National Security...

On September 18, 2020, the U.S. Department of Commerce issued two orders identifying the specific transactions related to the WeChat and TikTok mobile applications ("Orders") that are prohibited pursuant to Executive Orders...more

Executive Orders on TikTok and WeChat: Ambiguity and a Few Other Takeaways

On August 6, 2020, the White House issued two executive orders purportedly intended to "address[] the threat posed by" TikTok and WeChat, considered by the White House to be Chinese-owned mobile applications. The broadly...more

8/10/2020  /  CFIUS , Executive Orders , TikTok

Buyer Beware: Stepped Up Enforcement and Monitoring by CFIUS

On June 9, 2020, the U.S. Department of the Treasury (Treasury) announced via its Twitter account that it had launched a website dedicated to the monitoring and enforcement functions of the Committee on Foreign Investment in...more

CFIUS Serves Up Proposed Changes to Mandatory Filing Rules: Bon Appétit!

On May 21, 2020, the Committee on Foreign Investment in the United States (CFIUS) published proposed rules (the Proposals) that fine-tune the recently implemented changes to the CFIUS rules. In particular, the Proposals...more

5/29/2020  /  CFIUS , Foreign Investment , Technology

CFIUS Filing Fees Finalized: Prepare to Pay (or Not)

On April 28, 2020, the Treasury Department (Treasury) issued an interim final rule, effective May 1, regarding filing fees for submissions to the Committee on Foreign Investment in the United States (CFIUS). The rule makes...more

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