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
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
9/22/2020
/ Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
Mobile Apps ,
Office of Foreign Assets Control (OFAC) ,
Online Platforms ,
Personal Data ,
Popular ,
Sanctions ,
Social Media ,
Software Developers ,
Surveillance ,
TikTok ,
Trump Administration ,
U.S. Commerce Department ,
WeChat
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
9/21/2020
/ Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
Mobile Apps ,
Office of Foreign Assets Control (OFAC) ,
Online Platforms ,
Personal Data ,
Popular ,
Sanctions ,
Social Media ,
Software Developers ,
Surveillance ,
TikTok ,
Trump Administration ,
U.S. Commerce Department ,
WeChat
Introduction: A New National Security Review Process -
On April 4, 2020, President Trump issued an Executive Order creating the Committee for the Assessment of Foreign Participation in the United States Telecommunications...more
CFIUS Past, Present, and Future:
A 2018 CFIUS Carol -
The year 2018 was a turning point in the history of the Committee on Foreign Investment in the United States (CFIUS). CFIUS’s change in direction in 2017 suggested that a...more
12/21/2018
/ CFIUS ,
China ,
Corporate Counsel ,
Cross-Border Transactions ,
Emerging Technology Companies ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Governments ,
Foreign Investment ,
National Security ,
Trump Administration
As of November 10, 2018, foreign investors making acquisitions and equity investments into many U.S. businesses will be required to file their investments with the Committee on Foreign Investment in the United States (CFIUS)...more
10/19/2018
/ CFIUS ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Emerging Technology Companies ,
Export Controls ,
Federal Pilot Programs ,
Filing Requirements ,
FIRRMA ,
Foreign Investment ,
NAICS ,
National Security ,
Trump Administration ,
U.S. Commerce Department
So you've heard a lot about CFIUS reform and the changes that may result from FIRRMA, perhaps from our prior pieces. While the President just signed FIRRMA into law on August 13, you probably know that many key FIRRMA...more