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Due Diligence U.S. Treasury

Fox Rothschild LLP

Treasury Revises Proposed Limits on China Tech Investments

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Revised regulations restricting investments in Chinese companies developing semiconductors and microelectronics, quantum information technologies, and artificial intelligence systems are taking shape and could soon be in...more

Morrison & Foerster LLP

New Sheriff in Town: Treasury Proposes Unprecedented Outbound Investment Screening Regulations

On June 21, 2024, the Biden administration rolled out its outbound investment screening regulations. Last year, the Biden administration published an advanced notice of proposed rulemaking (ANPRM) that outlined the broad...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations on the Electric Vehicle Credits Under Section 30D of the Internal Revenue Code

The Final Regulations provide relief with respect to “impracticable-to-trace” battery materials. The new guidance provides additional detail for the transition rule applicable to qualified manufacturers, including as...more

Jones Day

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

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The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more

American Conference Institute (ACI)

Industry Responses to the U.S. Outbound Investment Regulatory Regime

The only thing truly certain about the proposed U.S. outbound investment regulatory regime is that a lot of uncertainty remains. But industry responses garnered during the comment period may, at least partly, foretell the...more

Snell & Wilmer

CFIUS & Export Controls: The Foreign Investment Regulations Putting Buyers, Sellers, and M&A Practitioners at Risk

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In recent memory, enforcement of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) regulations has been mostly limited and sporadic. But recently, the U.S. government is reviving and...more

Morrison & Foerster LLP

Outbound Investment Review Program – Themes from Industry Comments

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As discussed in our September 2023 Lawfare article, the Biden administration’s first-of-its-kind outbound investment review program seeks to limit outbound investments by U.S. investors in Chinese developers of certain...more

Perkins Coie

FFIEC BSA/AML Exam Manual Updates - Implications for Banks

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The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more

Husch Blackwell LLP

FinCEN Shines Additional Light on the Corporate Transparency Act - FAQs and Summary Materials Now Available

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Overview- Below is an update to our April 6, 2022, client alert discussing the proposed regulations for the Corporate Transparency Act (CTA) and our October 14, 2022, client alert discussing the CTA Final Regulations as...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2023 - OFAC Enforcement Trends – Lack of Due Diligence in Mergers and Acquisitions

With roughly 12,000 names now associated with the Specially Designated Nationals and Blocked Persons List (“SDN”), layered sanctions on activities with Russia, and growing sanctions on China activities, U.S. sanctions have...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

King & Spalding

FinCEN Requests Comments on Beneficial Ownership Reporting Requirement; FinCEN’s Request For Information Moves U.S. Towards...

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The United States Department of the Treasury (“Treasury”) is taking further action to combat corruption, money laundering, terrorist financing, tax fraud, and other illicit activities. Following its Advance Notice of...more

BCLP

US, EU Issue Guidance on Expectations for Due Diligence to Address Forced Labor Risks

BCLP on

On July 13, 2021, the US Department of State, US Department of the Treasury, US Department of Commerce, US Department of Homeland Security, Office of the United States Trade Representative, and US Department of Labor issued...more

Vinson & Elkins LLP

OFAC Announces a Civil Settlement Agreement For Multiple Sanctions Violations Related To Digital Currency Transactions

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On February 18, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a half-million dollar settlement with BitPay, Inc. (“BitPay”), a U.S. company that processes digital currency...more

Snell & Wilmer

New Year, New Laws – Congress Passes Major Anti-Money Laundering Act

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On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more

Morrison & Foerster LLP

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more

ArentFox Schiff

Pentagon Identifies 20 ‘Communist Chinese Military Companies’

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As the US technology competition with China continues to intensify, the Trump Administration has taken another step to tighten the screws on China. In late June, the US Department of Defense (DoD) made public a list of 20...more

Cozen O'Connor

U.S. Government Issues Sanctions Advisory for the Maritime Industry and Energy and Metals Sectors

Cozen O'Connor on

On May 14, 2020, the U.S. Department of State, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the U.S. Coast Guard jointly released a Sanctions Advisory for the Maritime Industry, Energy and...more

Proskauer - New Media & Technology

Final CFIUS Regulations Impact Foreign Non-Control Investment Transactions Involving Critical Technologies/Infrastructure or...

In 2018, Congress passed the Foreign Investment Risk Review Modernization Act (FIRRMA) to modernize the Committee on Foreign Investment in the United States (CFIUS). CFIUS is chaired by the Secretary of the Treasury and is...more

Bradley Arant Boult Cummings LLP

Is the Bank Open? Federal Agencies Clarify Regulatory Requirements for Banking Hemp

On December 3, several federal agencies issued guidance (Guidance) that, by its terms, “provide[s] clarity” regarding “the regulatory requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related...more

Pillsbury Winthrop Shaw Pittman LLP

The United States Updates Sanctions to Combat Terrorism with New Focus on Non-U.S. Banks

As it targets terrorist groups and their finances, the U.S. Government announces potent secondary sanctions that can impede correspondent banking relationships of non-U.S. banks. A new U.S. Executive Order updates the...more

Seyfarth Shaw LLP

Culture of Compliance: M&A Transactions Subject To U.S. Department of Treasury Scrutiny

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Seyfarth Synopsis: On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released explicit guidance outlining its expectations for effective written sanctions compliance programs...more

Dechert LLP

OFAC Clarifies, and Further Complicates, Sanctions on Venezuela, PdVSA

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On February 1, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued guidance in the form of Frequently Asked Questions (“FAQs”) relating to sanctions imposed on January 28, 2019 against...more

Akin Gump Strauss Hauer & Feld LLP

Podcast: CFIUS and FIRRMA: What You Need to Know

In this episode, Akin Gump international trade partners Tatman Savio and Christian Davis discuss the Committee on Foreign Investment in the U.S. (CFIUS) and how the new Foreign Investment Risk Review Modernization Act...more

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