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President Trump issues “America First Investment Policy” presidential memorandum

On February 21, 2025, President Trump issued a memorandum “America First Investment Policy” (the Investment Memo or Memo), in which the President aims to modify the US Government’s approach to inbound and outbound foreign...more

Tariffs and Trump 2.0 - the art of the deal or the end game?

In his first tangible action implementing his campaign promise to impose broad tariffs, on February 1, 2025, President Trump issued three Executive Orders (the EOs) directing that across-the-board tariffs be imposed on goods...more

New BIS rule on connected cars: Prohibitions on technology from Russia and China

On January 16, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule prohibiting the sale or import into the United States of passenger vehicles containing certain hardware or...more

New export controls on AI model weights and advanced computing integrated circuits -- supply chain complexity increases

On January 15, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) published an interim final rule (IFR) that imposes new controls on advanced computing integrated circuits (Advanced ICs) and certain...more

Treasury releases proposed Outbound Investment Security Program rules

On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more

Treasury proposes expansion of CFIUS authorities

On April 11, 2024, the US Department of the Treasury issued, for notice and comment, proposed modifications (Proposed Rule) to certain Committee on Foreign Investment in the United States (CFIUS or Committee) regulations. In...more

The long-awaited US outbound investment program - what’s proposed and what’s the scope and effect

After months of deliberation, on August 9, 2023, President Biden issued the executive order “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (Order), with...more

Treasury’s 2022 CFIUS Annual Report - Highlights and Observations: Greater scrutiny of national security risk in foreign...

On July 31, 2023, the US Department of the Treasury-led Committee on Foreign Investment in the United States (CFIUS or the Committee) released its annual report for calendar year 2022 (2022 Report), which provides insight...more

The recently enacted 2023 National Defense Authorization Act adopts federal procurement restrictions for certain covered Chinese...

Amid the 4,000 pages of provisions in the recently enacted Fiscal Year 2023 National Defense Authorization Act (NDAA) are prohibitions and associated requirements relating to the federal procurement of certain Chinese...more

Commerce Department offers guidance on new controls on US person activities supporting the development or production of integrated...

Recently, the US Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule imposing additional export controls on certain advanced computing and semiconductor manufacturing items and for...more

President Biden issues Executive Order modifying, but mostly retaining, the Trump Era Chinese Military Company securities ban 

On June 3, 2021, in one of his first major China-related actions, President Biden issued an Executive Order that amends, but keeps intact the core elements of, previous orders issued by President Trump prohibiting US Persons...more

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