On July 8, 2024, the U.S. Department of the Treasury ("Treasury") issued a proposed rule to expand the Committee on Foreign Investment in the United States' ("CFIUS") jurisdiction over certain categories of foreign investment...more
The Situation: On June 21, 2024, the U.S. Department of the Treasury ("Treasury") issued a notice of proposed rulemaking to implement President Biden's executive order mandating national security review of certain U.S....more
On April 11, 2024, the Treasury Department announced a prepublication copy of a proposed rule amending the regulations of the Committee on Foreign Investment in the United States ("CFIUS") (the "Proposed Rule")....more
In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more
8/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Agents Registration Act (FARA) ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
The Biden administration has issued a long-anticipated executive order targeting U.S. outbound investment in certain Chinese industries; however, significant steps remain before these measures are fully implemented....more
8/22/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Comment Period ,
Executive Orders ,
Final Rules ,
Foreign Investment ,
National Security ,
Outbound Transactions ,
Popular ,
U.S. Treasury
The Situation: On August 7, 2020, the U.S. Department of the Treasury ("Treasury Department") took the first action under the authority of "The President's Executive Order on Hong Kong Normalization" ("HK Normalization EO")...more
The Situation: On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act (the "HKAA"), the U.S. government's response to China's new National Security Law for Hong Kong.
The Result: The HKAA could...more
7/24/2020
/ Blocking Sanctions ,
China ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Supply Chain ,
Trump Administration ,
U.S. Treasury ,
US State Departments ,
US Trade Policies
The Situation: The U.S. Department of the Treasury ("Treasury Department") recently issued proposed regulations that will alter and in some cases expand the scope of critical technology foreign investments subject to...more
6/23/2020
/ CFIUS ,
Critical Infrastructure Sectors ,
Export Administration Regulations (EAR) ,
Export Controls ,
FIRRMA ,
Foreign Investment ,
ITAR ,
National Security ,
New Rules ,
Proposed Regulation ,
U.S. Treasury
The Situation: The U.S. Department of the Treasury ("Treasury Department") released final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA"), which, among other things, effectuate...more
1/29/2020
/ CFIUS ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
FIRRMA ,
Foreign Governments ,
Foreign Investment ,
NAICS ,
National Security ,
Personal Data ,
Principal Place of Business ,
U.S. Treasury
The Situation: The U.S. Department of the Treasury ("Treasury") proposed regulations that for the first time subject certain real estate transactions to the jurisdiction of the Committee on Foreign Investment in the United...more