On 24 March 2025, the White House issued an Executive Order threatening to impose a 25% tariff on all goods imported into the United States from any country that imports Venezuelan oil directly or indirectly through third...more
On 21 February 2025, President Donald J. Trump signaled his administration’s approach to foreign investment policy with a presidential memorandum, “America First Investment Policy” (The Policy). Among the most significant...more
Introduction - On 28 October 2024, the US Treasury Department issued a Final Rule implementing the Outbound Investment Program (OIP) under Executive Order 14105, which safeguards US national security by limiting investments...more
On 28 October, US Treasury issued new rules that restrict investment in Chinese development of semiconductors, quantum computing and AI (Covered Activity). Taking effect on 2 January 2025, the new rules are based on findings...more
On 21 June 2024, the Office of Investment Security of the US Department of the Treasury (Treasury) issued proposed regulations to implement President Biden’s August 2023 Executive Order on Addressing United States Investments...more
6/27/2024
/ CFIUS ,
China ,
Civil Monetary Penalty ,
Critical Infrastructure Sectors ,
Executive Orders ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
Investment ,
National Security ,
Prohibited Transactions ,
Proposed Regulation ,
Supply Chain ,
U.S. Treasury
On 17 October 2023, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued two new Interim Final Rules (collectively, the Updated Rule) that significantly revise and expand controls under the US Export...more
10/30/2023
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
End-Users ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Interim Final Rules (IFR) ,
National Security ,
Semiconductors ,
U.S. Commerce Department
On 9 August 2023, President Biden issued a long anticipated executive order imposing certain limitations, reporting requirements, and prohibitions on outbound investment from the United States into certain sensitive industry...more
Earlier this month, the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) took two noteworthy actions that underscore the Committee’s powerful role in reviewing foreign direct investment and...more
On January 13, 2020, the U.S. Department of the Treasury (“Treasury”) published two final rules (“Final Rules,” found here and here) that implement most of the remaining provisions of the Foreign Investment Risk Review...more
On November 27, 2019, the Department of Commerce (“Commerce”) issued a proposed rule implementing Executive Order (“EO”) 13873, “Securing the Information and Communications Technology and Services Supply Chain,” issued on May...more
On September 24, 2019, the U.S. Department of the Treasury (“Treasury”) published two proposed rules (together, the “Proposed Rules”) to implement the remaining provisions of the Foreign Investment Risk Review Modernization...more
On August 6, the D.C. Circuit Court of Appeals unsealed its partly redacted decision upholding a civil contempt order against three foreign banks that refused to comply with a subpoena from U.S. authorities to produce bank...more
OVERVIEW -
- Oversight of Foreign Investment & Tech Transfer
- CFIUS Reforms – FIRRMA
- Investment Strategies
FOREIGN INVESTMENT & TECH OVERSIGHT -
- The Committee on Foreign Investment in the United States...more
6/27/2019
/ CFIUS ,
Economic Sanctions ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
FIRRMA ,
Foreign Investment ,
Imports ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Section 232 ,
Section 301 ,
Tariffs ,
Trade Relations ,
US Trade Policies
Two major actions by the Committee on Foreign Investment in the United States (“CFIUS”) have recently come to light that underscore the significant risks of investments in U.S. businesses that have large volumes of sensitive...more
President Trump has authorized investigations into whether steel imports and aluminum imports impair U.S. national security. All categories of steel and aluminum products from all countries are under review. The...more