On November 18, 2024, the U.S. Department of the Treasury issued a final rule enhancing the mitigation monitoring and enforcement tools of the Committee on Foreign Investment in the United States (CFIUS or the "Committee")....more
11/25/2024
/ CFIUS ,
Compliance ,
Compliance Monitoring ,
Corporate Counsel ,
Enforcement Authority ,
Filing Requirements ,
Final Rules ,
FIRRMA ,
Foreign Investment ,
National Security ,
U.S. Treasury
As the lead agency for the Committee on Foreign Investment in the United States (CFIUS or the Committee), the U.S. Department of the Treasury released new proposed rules on April 11, 2024 intended to enhance the enforcement...more
5/6/2024
/ Administrative Procedure ,
CFIUS ,
Civil Monetary Penalty ,
Comment Period ,
Compliance ,
Enforcement ,
Enforcement Authority ,
FIRRMA ,
Jurisdiction ,
Mitigation ,
Proposed Rules ,
Real Estate Transactions ,
U.S. Treasury
With the current state of the world and heightened scrutiny of the nonprofit sector, it is critical that nongovernmental organizations (NGOs) with international reach routinely assess the effectiveness of their trade...more
2/27/2024
/ Compliance ,
Cross-Border Transactions ,
Economic Sanctions ,
Export Controls ,
Foreign Policy ,
Internal Controls ,
International Relations ,
International Travel ,
Know Your Customers ,
National Security ,
NGOs ,
Nonprofits ,
Policies and Procedures ,
Risk Assessment ,
Risk Management
As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more
1/24/2024
/ Air Cargo ,
Air Carriers ,
Bureau of Industry and Security (BIS) ,
China ,
Common Carriers ,
Compliance ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Extraterritoriality Rules ,
Freight Forwarding ,
Iran ,
Maritime Transport ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Russia ,
Shipping ,
Shipping Cargo ,
Vessels
Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more
8/2/2023
/ Bank Secrecy Act ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Cooperation ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Export Controls ,
Exports ,
FinCEN ,
Joint Statements ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Prohibited Transactions ,
Remediation ,
Self-Reporting ,
Totality of Circumstances Test ,
Voluntary Disclosure ,
Whistleblowers
On October 20, 2022, the Committee on Foreign Investment in the United States (CFIUS or Committee) issued novel Enforcement and Penalty Guidelines (Guidelines), which emphasize the enforcement aspect of its legal...more
On June 24, 2022, the Federal Maritime Commission’s Office of the General Counsel issued an opinion on the effective date of the new Ocean Shipping Reform Act of 2022 (“OSRA 2022”), Pub. L. 117-146. Per the General Counsel,...more