The U.S. Department of Defense released the final rule implementing the Cybersecurity Maturity Model Certification on Sept. 9. Through the program, the DOD seeks to enhance protections for sensitive information.
Originally...more
10/10/2025
/ Controlled Unclassified Information (CUI) ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Defense Sector ,
Department of Defense (DOD) ,
DFARS ,
Export Controls ,
False Claims Act (FCA) ,
Federal Contractors ,
Fraud ,
ITAR ,
Risk Assessment
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently implemented the long-anticipated 50% ownership standard (or Affiliates Rule) to extend the licensing requirements under the Export...more
10/6/2025
/ Affiliates ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Due Diligence ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
License Applications ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
U.S. Commerce Department
Contractors should closely monitor their customer and regulatory agencies’ websites for shutdown guidance, as agencies such as the Department of Defense (DoD), U.S. Department of Justice (DOJ), and others have already issued...more
10/2/2025
/ Anti-Deficiency Act ,
Appropriations Bill ,
Contract Disputes ,
Contract Management ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Funding ,
Government Shutdown ,
Risk Management ,
Trump Administration
On September 10, the U.S. Department of Defense (DOD) posted its final rule implementing the Cybersecurity Maturity Model Certification (CMMC) program for defense acquisitions. This new rule (acquisition rule) updates the...more
10/1/2025
/ Acquisitions ,
Controlled Unclassified Information (CUI) ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Defense Contracts ,
Department of Defense (DOD) ,
DFARS ,
Federal Contractors ,
NIST ,
Regulatory Requirements ,
Subcontractors
On September 19, the U.S. Department of the Treasury issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public input on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins...more
9/23/2025
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
FinTech ,
Investment ,
Proposed Rules ,
Public Comment ,
Regulatory Requirements ,
Stablecoins ,
The GENIUS Act ,
Trump Administration ,
U.S. Treasury
The Report authored by the Presidential Working Group on Digital Assets Markets (PWG), titled “Strengthening American Leadership in Digital Financial Technology,” along with the accompanying fact sheet, outlines several key...more
9/19/2025
/ AML/CFT ,
Banks ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Cybersecurity ,
Data Privacy ,
Digital Assets ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinTech ,
Investment ,
Securities and Exchange Commission (SEC) ,
Trump Administration
In this episode of The Crypto Exchange, hosts Ethan Ostroff and Genna Garver are joined by their colleague Pete Jeydel to explore the implications of the GENIUS Act on sanctions, anti-money laundering (AML), and efforts to...more
9/16/2025
/ AML/CFT ,
Anti-Money Laundering ,
Digital Assets ,
Economic Sanctions ,
FinCEN ,
New Legislation ,
Regulatory Requirements ,
Stablecoins ,
Terrorist Financing Regulations ,
The GENIUS Act ,
U.S. Treasury
On August 28, 2025, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published a rule relaxing certain restrictions on Syria under the Export Administration Regulations (EAR). But unlike the much broader...more
9/3/2025
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
ECCNs ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Licensing Rules ,
New Guidance ,
New Rules ,
Regulatory Reform ,
State Sponsors of Terrorism ,
Syria ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
The release of the “America First” investment policy memorandum on Feb. 21 was a glimpse into the Trump administration’s approach to foreign investment oversight, particularly for the Committee on Foreign Investment in the...more
8/28/2025
/ America First Trade Policy ,
Brownfield Properties ,
CFIUS ,
FIRRMA ,
Foreign Investment ,
Greenfield Projects ,
National Security ,
New Regulations ,
Real Estate Development ,
Real Estate Investments ,
Real Estate Transactions ,
Regulatory Oversight ,
Trump Administration
President Trump signed into law the Export Control Transparency Act. While this new law includes a confidentiality provision, organizations submitting export license applications to the Commerce Department’s Bureau of...more
In this episode of Payments Pros, Carlin McCrory is joined by Pete Jeydel, a partner in the firm's White Collar Litigation + Investigations Practice Group, to discuss the new Department of Justice (DOJ) Data Security Program...more
On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...more
7/15/2025
/ Acquisition Agreements ,
Cuban Assets Control Regulations (CACR) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Subsidiaries ,
International Trade ,
Merger Agreements ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Sanctions ,
U.S. Treasury
On June 30, 2025, President Trump issued an executive order (EO) that, effective July 1, revokes the U.S. sanctions program on Syria, and calls for the removal of the Syrian Sanctions Regulations from the Code of Federal...more
On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more
6/17/2025
/ Civil Monetary Penalty ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Investment ,
Investment Funds ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Subpoenas ,
Venture Capital
On May 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 25 (GL 25), effectively lifting most sanctions imposed under the Syrian Sanctions Regulations (SSR) (31...more
We are pleased to share with you our latest publication, “Navigating Change: First 100 Days under the Trump Administration,” authored by our Digital Assets + Blockchain team. This retrospective examines the pivotal...more
5/29/2025
/ Blockchain ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
Government Agencies ,
Investment Opportunities ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Requirements ,
Securities Regulation ,
Trump Administration
On May 8, the Treasury Department announced a plan to introduce a new Known Investor portal as a key component of the “fast-track” process for investments by U.S. allies and partners under review by the Committee on Foreign...more
The Treasury Department has taken initial steps to implement the Trump administration’s “total elimination” policy directed at certain drug trafficking cartels. Most recently, on May 1, Treasury’s Financial Crimes Enforcement...more
5/9/2025
/ Border Security ,
Cartels ,
Crude Oil ,
Economic Sanctions ,
Financial Crimes ,
FinCEN ,
Foreign Trade Regulations ,
Mexico ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Smuggling ,
Terrorist Acts
There are unprecedented risks and opportunities emerging for companies in the energy sector as the Trump administration’s priorities start to come into focus. Many of those are well-known to the industry. Here’s one that’s...more
5/6/2025
/ Bulk Electric System ,
Bureau of Industry and Security (BIS) ,
China ,
Clean Energy ,
Emerging Technology Companies ,
Energy Reform ,
Energy Storage ,
Executive Orders ,
Foreign Adversaries ,
Information Technology ,
Infrastructure ,
National Security ,
Oil & Gas ,
Regulatory Requirements ,
Risk Management ,
Trump Administration ,
U.S. Commerce Department
The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward....more
4/25/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Enforcement Actions ,
Export Controls ,
Final Rules ,
Foreign Policy ,
Information Technology ,
National Security ,
Risk Assessment ,
Risk Management ,
Software ,
Supply Chain ,
U.S. Commerce Department ,
US Trade Policies
The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward.
Originally...more
4/24/2025
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Executive Orders ,
Export Controls ,
Final Rules ,
Foreign Adversaries ,
Information Technology ,
National Security ,
Risk Management ,
Software ,
Supply Chain ,
U.S. Commerce Department
The new Department of Justice (DOJ) Data Security Program (DSP) took effect on April 8....more
4/17/2025
/ Corporate Counsel ,
Covered Person ,
Cybersecurity ,
Data Brokers ,
Data Protection ,
Data Security ,
Department of Justice (DOJ) ,
Due Diligence ,
New Guidance ,
Penalties ,
Risk Management
President Trump signed a new executive order, “Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment” (the Order) on April 9, marking yet another significant shift in U.S. trade policy. The...more
4/14/2025
/ China ,
Executive Orders ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
In this episode of Crypto Exchange, host Ethan Ostroff is joined by his colleagues Pete Jeydel and Peter Leary to discuss trends and lessons learned from recent civil enforcement actions by the Treasury Department's Office of...more
Under the Department of Justice’s (DOJ) “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” rules (the Rules), allowing access outside the United States...more
4/4/2025
/ China ,
Data Security ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Final Rules ,
National Security ,
New Regulations ,
Personal Data ,
Regulatory Reform ,
Russia ,
Trump Administration