On May 1, 2024, the U.S. State Department published a proposed rule to reduce International Traffic and Arms Regulations (ITAR) licensing requirements for the transfer of defense articles or services between the United...more
5/3/2024
/ AUKUS ,
Customs and Border Protection ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
ITAR ,
NDAA ,
Proposed Rules ,
Transportation Industry ,
US Department of State
On April 11, 2024, the Committee on Foreign Investment in the United States (CFIUS) issued a proposed update expanding its mitigation and enforcement provisions, the first such action since the enactment of the Foreign...more
On December 1, 2022, the Federal Maritime Commission (FMC or the Commission) released “Interim Procedures for Processing Charge Complaints” filed with the Commission under the Ocean Shipping Reform Act of 2022 (OSRA 22). In...more
On October 20, 2022, the U.S. Department of Treasury, acting in its role as Chair of the Committee on Foreign Investment in the United States (CFIUS), published a new set of “Enforcement Penalty and Guidelines” (the...more
On September 15, 2022, President Biden signed an Executive Order (EO), which connects the work carried out by the Committee on Foreign Investment in the United States (CFIUS or the Committee) to the Administration’s national...more
9/23/2022
/ Artificial Intelligence ,
Biden Administration ,
Biotechnology ,
CFIUS ,
Critical Infrastructure Sectors ,
Cybersecurity ,
Executive Orders ,
Foreign Investment ,
National Security ,
OSTP ,
Popular ,
Sensitive Personal Information ,
Supply Chain ,
U.S. Treasury
On April 6, 2022, the House Committee on Oversight and Reform passed H.R. 7185, the Federal Contracting for Peace and Security Act, which would prohibit the U.S. government (USG) from contracting with any companies continuing...more
In the wake of Russia’s incursion into Ukraine, the United States has over the past several days imposed a series of unprecedented economic sanctions and export controls designed to prevent President Vladimir Putin from...more
3/8/2022
/ Bureau of Industry and Security (BIS) ,
Debt-Equity ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Ukraine
On September 24, 2021, the Safer Federal Workforce Task Force (task force) issued its anticipated guidance for federal contractors and subcontractors pursuant to President Biden’s Executive Order 14042 (the EO). Most...more
9/29/2021
/ Biden Administration ,
Coronavirus/COVID-19 ,
Employer Mandates ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Employees ,
Infectious Diseases ,
Subcontractors ,
Vaccinations ,
Workplace Safety
On September 9, 2021, President Biden announced an executive order (EO) that expands upon the administration’s goals of requiring both federal employees and contractors and subcontractors working in connection with federal...more
In a final rule issued last week, the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) has amended and reissued the Somalia Sanctions Regulations, which can be found in 31 C.F.R. Part 551....more
On April 27, 2021, President Biden issued his latest executive order (the EO), which requires all federal agencies to incorporate a $15 per hour minimum wage into nearly every federal contract effective January 2022....more
On April 15, 2021, President Biden issued Executive Order 14024 (the EO), imposing new sanctions on the Russian Federation in response to foreign election interference in the 2020 U.S. federal election and the SolarWinds...more
4/22/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
The Paycheck Protection Program is scheduled to expire March 31, 2021. However, the program still has a large amount of unspent money, and there is still considerable support for the program in Congress....more
On January 19, SBA issued an interim final rule governing forgiveness of Paycheck Protection Program loans and also issued new versions of the three forgiveness application forms, including a streamlined form for loans up to...more
As described in our previous Alert, the appropriations act signed on December 27, 2020, revived the original Paycheck Protection Program, with some changes (now referred to as a “first draw” loan) and created a new “second...more
The omnibus budget act signed by President Trump on December 27 reinstitutes the Paycheck Protection Program, with significant changes. The act allows new borrowers to receive PPP loans and some existing borrowers to receive...more
On September 15, 2020, the U.S. Department of the Treasury published a final rule, effective October 15, 2020, that alters and expands the scope of foreign investments involving critical technologies that are subject to...more
9/21/2020
/ CFIUS ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Emerging Technology Companies ,
Export Administration Regulations (EAR) ,
Filing Requirements ,
Foreign Investment ,
ITAR ,
NAICS ,
Regulatory Reform ,
Regulatory Requirements
On August 13, 2020, an interim final rule published by the Federal Acquisition Regulations Council (the Council) went into effect that prohibits the use of certain telecommunications equipment produced by Chinese entities...more
8/20/2020
/ China ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Foreign Adversaries ,
Huawei ,
National Security ,
Prohibited Transactions ,
Supply Chain ,
Telecommunications ,
Trump Administration ,
ZTE
On July 23, the Small Business Administration issued a procedural notice to lenders participating in the Paycheck Protection Program concerning PPP loan forgiveness, to announce that SBA will begin accepting forgiveness...more
We want to make readers aware of two significant recent developments relating to the Paycheck Protection Program (PPP). Additional information on the program and its rules relating to eligibility, need for funding, loan...more
The Paycheck Protection Program Flexibility Act (Flexibility Act), which became effective June 5, significantly changed key elements of the Paycheck Protection Program (PPP), as discussed in Cozen O’Connor’s Alerts posted on...more
6/20/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Loan Applications ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Paycheck Protection Program Flexibility Act of 2020 (PPPFA) ,
Payroll Taxes ,
Required Forms ,
SBA ,
Small Business ,
Small Business Loans
The Paycheck Protection Program Flexibility Act of 2020 (Flexibility Act), which became law on June 5, made significant changes in the Paycheck Protection Program (PPP)....more
The Paycheck Protection Program Flexibility Act of 2020 (the Flexibility Act) was signed into law Friday. The Flexibility Act makes significant changes in the Paycheck Protection Program (PPP) originally adopted as part of...more
On May 22, the SBA issued two new rules that provide some additional insight into Paycheck Protection Program (PPP) loan forgiveness and for the first time explain the process for lenders and the SBA to review PPP loans and...more
The SBA has published its long-awaited guidance on forgiveness of Paycheck Protection Program (PPP) loans — SBA Form 3508, the Loan Forgiveness Application....more