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The CFIUS “Fast-Track” Pilot Program: Why You (Probably) Can Ignore This Space

On May 8, 2025, the U.S. Department of the Treasury (Treasury) announced that it will create a “fast-track pilot program” for certain foreign investors. The stated goal of the program is to streamline investment reviews by...more

President Trump Issues “America First Investment Policy”

On February 21, 2025, the White House released a memorandum titled, “America First Investment Policy” (the Memorandum). The Memorandum describes how this Administration plans to address U.S. national security risks stemming...more

The New National Security Rules for Investing U.S. Capital

A Guide to the New Diligence Questions for “Outbound” U.S. Investment - In late October 2024, the U.S. Treasury Department (Treasury) issued its final rules (the Outbound Rules) implementing President Biden’s Executive Order...more

Sustainability and ESG Advisory Practice Update, July 2024

We are pleased to share the July 2024 issue of Wilson Sonsini's Sustainability and ESG Advisory Practice Update. Each issue combines news, key legal developments, and resources related to sustainability and environmental,...more

Proposed "Outbound Investment" Regulations Target Transactions Involving PRC Semiconductor, Quantum, and AI Businesses

New Regulations Will Require Additional Diligence for a Broad Array of Transactions, Including Many Investments in U.S. and Global Businesses - On June 21, 2024, the U.S. Treasury Department (Treasury) issued a Notice of...more

FinCEN Releases Proposed Rule Designating CVC Mixing as a “Primary Money Laundering Concern”

On October 23, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (proposed rule) addressing “mixing transactions” that involve convertible...more

Beware: Increasingly Aggressive Enforcement Actions in the Crypto Asset Industry Puts Companies on Notice

Regulators are increasingly taking enforcement action against crypto asset industry participants for violating anti-money laundering (AML) and sanctions laws. Regulators are concerned about the illicit use of crypto...more

Treasury Risk Assessment Emphasizes That Decentralized Crypto Companies Have AML and Sanctions Compliance Obligations

Earlier this month, the U.S. Department of the Treasury (Treasury) released its Illicit Finance Risk Assessment of Decentralized Finance (Assessment). This Assessment, part of a broad regulatory scrutiny of entities that...more

Focus on Fintech – Q4 2022

In this latest issue of Wilson Sonsini's Focus on Fintech newsletter, we discuss the FTX bankruptcy and the increased federal regulatory scrutiny of crypto assets, and new rules and innovations in the payments...more

Is Regulation of NFTs to Combat Financial Crime on the Horizon?

On February 4, 2022, the United States Department of the Treasury (the Treasury) issued a report titled, "Study of the Facilitation of Money Laundering and Terror Finance Through the Trade in Works of Art." The report...more

New Rules Will Require Beneficial Ownership Reporting to Federal Regulators by U.S. and Foreign Corporations, LLCs, and Other...

On December 8, 2021, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) published its proposed regulations on beneficial ownership information (BOI) reporting requirements. These FinCEN regulations will...more

National Cryptocurrency Enforcement Team Turns Up the Crypto Heat

Earlier this month, the U.S. Department of Justice (DOJ) announced the creation of a National Cryptocurrency Enforcement Team (NCET) to "tackle complex investigations and prosecutions of criminal misuses of cryptocurrency,...more

Fees and Loathing at CFIUS: The Committee Imposes Filing Fees, Forces Divestment, and Reportedly Blocks Another Big Deal

For an entity that has historically placed an emphasis on maintaining the secrecy of its proceedings, the Committee on Foreign Investment in the United States (CFIUS, or the Committee) has recently attracted quite a few...more

What Technology Businesses and Investors Should Know About the New CFIUS Rules

A Summary and a Business Decision-Maker's Chart for the Path Forward - On January 13, 2020, the U.S. Department of the Treasury issued final rules fully implementing the new powers granted to the Committee on Foreign...more

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