News & Analysis as of

U.S. Treasury Enforcement

A&O Shearman

CFIUS Update: 2023 Report to Congress and new enforcement website

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The Committee on Foreign Investment in the United States (CFIUS) continues to play an increasingly active role in reviewing and assessing inbound investment transactions for U.S. national security risks. In this alert, we...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - June 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

Paul Hastings LLP on

Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

ArentFox Schiff

As the (Customs and Trade) World Turns: July 2024

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Welcome to the July 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

Freiberger Haber LLP on

The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

King & Spalding

Department of Treasury Issues Proposed Rule Covering Outbound Investments

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Regulations ultimately will implement a new program restricting certain investments related to China- On June 21, 2024, the U.S. Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (the “Rule”)...more

Proskauer - Regulatory & Compliance

CFIUS Developments Counsel Caution for In-bound U.S. Investment

With an eye towards preserving and expanding the gatekeeper role in national security, the Committee on Foreign Investment in the United States (CFIUS) has issued proposed rules to strengthen enforcement....more

Venable LLP

CFIUS Proposes Increased Penalties for Noncompliance and Updated Mitigation and Enforcement Rules

Venable LLP on

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

Eversheds Sutherland (US) LLP

Treasury proposes expansion of CFIUS authorities

On April 11, 2024, the US Department of the Treasury issued, for notice and comment, proposed modifications (Proposed Rule) to certain Committee on Foreign Investment in the United States (CFIUS or Committee) regulations. In...more

Bass, Berry & Sims PLC

CFIUS Update: Larger Penalties, Sharper Monitoring

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On April 11, the U.S. Treasury Department promulgated a Notice of Proposed Rulemaking (NPRM) amending the regulations that govern the operations of the Committee on Foreign Investment in the United States (CFIUS) to increase...more

Pillsbury - Global Trade & Sanctions Law

Treasury Announces Proposed Rule to Update CFIUS Regulations and Bolster Enforcement

On April 11, 2024, the U.S. Department of the Treasury (Treasury), as Chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM), which is the first substantive...more

Torres Trade Law, PLLC

Less Bark and More Bite? CFIUS Proposed Rule Enhancing Enforcement Capabilities

Torres Trade Law, PLLC on

A new proposed rule issued by the Committee on Foreign Investment in the United States (CFIUS) seeks to expand the scope of information that CFIUS can request from parties, expand its ability to monitor and investigate...more

Akin Gump Strauss Hauer & Feld LLP

CFIUS Proposes Expanded Enforcement Authorities and Increased Penalties

Key Points - On April 15, 2024, the Treasury Department published a proposed rule that would amend the Committee on Foreign Investment in the United States (CFIUS) regulations to expand CFIUS’s enforcement authorities....more

Latham & Watkins LLP

Treasury Proposes New CFIUS Regulations to Expand Monitoring and Enforcement Authorities: 5 Key Takeaways

Latham & Watkins LLP on

The proposal signals a continued effort to expand CFIUS’s enforcement scope and update penalties. On April 11, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed Rulemaking (the Proposed Rule)...more

Dechert LLP

CFIUS’ Proposed Rules Enhance its Enforcement Authority

Dechert LLP on

The U.S. Department of Treasury (“Treasury”), which is Chair of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”), released a Notice of Proposed Rulemaking on April 11, 2024 (“NPRM”) meant...more

Wiley Rein LLP

Treasury Proposes Stronger CFIUS Penalties, Broader Subpoena and Enforcement Powers

Wiley Rein LLP on

The U.S. Department of the Treasury (Treasury), which chairs the Committee on Foreign Investment in the United States (CFIUS or the Committee), recently published a Notice of Proposed Rulemaking (NPRM) that would amend the...more

King & Spalding

Congressmembers Send Letter to Departments Raising Provider Concerns with No Surprises Act Implementation

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On March 18, 2024, thirty-nine (39) members of the United States House of Representatives sent a letter urging federal agencies to finalizing rulemaking regarding the implementation of the No Surprises Act. The letter,...more

A&O Shearman

U.S. sanctions enforcement in the virtual currency space - USD 1 billion and counting...

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Beginning in 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has increasingly focused its enforcement activity on entities operating in the virtual currency space, illustrating a trend that...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...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

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 3

Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Seward & Kissel LLP

Full Steam Ahead on Russia Sanctions

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2024 has already been a busy year for sanctions on Russia, with the implementation of new sanctions and intensifying enforcement of existing sanctions authorities, with no signs of slowing down....more

Dunlap Bennett & Ludwig PLLC

What Is The Corporate Transparency Act?

The Corporate Transparency Act was passed by Congress with bipartisan support in 2021 and went into effect on January 1, 2024. Broadly speaking, the law requires private companies to file a report with the Department of...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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

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December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

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