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DOJ’s “Bulk Sensitive Data Rule” is in Effect, and May Require Significant Compliance Obligations as Enforcement is Set to Begin

Pursuant to a newly effective U.S. Department of Justice (DOJ) regulation, the transfer and storage of certain sensitive U.S. government and personal data may be prohibited or restricted, depending on the intended recipient,...more

Are There Legitimate Ways to Achieve More Advantageous Tariff Classifications?

With recent increases in U.S. tariffs and the increasing complexity of determining applicable duties for different products, importers are looking for ways to reduce their tariff exposure. Since a product’s tariff treatment...more

Bureau of Industry and Security – 2025 Update Conference on Export Controls and Policy

The 2025 BIS Update Conference on Export Controls and Policy wrapped up last week. Here are three main takeaways: 1. China is the Priority: The top three U.S. export controls and enforcement priorities for the new...more

Corporate Transparency Act Revived After Last Remaining Nationwide Preliminary Injunction is Lifted - Reporting Deadlines Extended

On February 18, 2025, the U.S. Federal District Court for the Eastern District of Texas lifted the last remaining nationwide preliminary injunction of the CTA in the Smith case. This follows a decision on January 23, 2025, by...more

Trump Administration Pauses FCPA Enforcement – Why Compliance Is Still Critical

On February 10, 2025, President Trump issued an executive order (EO) directing Attorney General Pam Bondi to effectively pause the Justice Department’s enforcement of the Foreign Corrupt Practices Act (FCPA). This was the...more

AG Bondi Overhauls FCPA Enforcement in Day 1 Memo

On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...more

Reverse CFIUS is Coming: President Biden Issues Executive Order Addressing Certain Outbound Investments by U.S. Persons

On August 9, 2023, President Biden issued an Executive Order (E.O.) addressing certain outbound investments by U.S. persons in certain sensitive or advanced technologies or products involving certain “countries of concern.”...more

CFIUS Year in Review

CFIUS reviewed a record number of transactions in 2021 according to its most recent annual report – and shows no signs of slowing down. High technology (including quantum computing), life sciences, and green energy...more

BIS Releases Statistics on Export Licenses to Huawei and SMIC Showing Majority of License Applications Were Approved

In response to a request from the ranking member of the House Foreign Affairs Committee, the Department of Commerce’s Bureau of Industry and Security (BIS) provided export license statistics related to Chinese firms Huawei...more

DOJ Issues New Policy Regarding Voluntary Disclosures of Export Controls and Sanctions Violations

In December, the Department of Justice (DOJ) announced the release of a new policy for business organizations regarding voluntary self-disclosures of export control and sanctions violations. The new Policy makes explicit that...more

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