President Donald Trump issued a presidential order (the Order) on July 8, 2025, retroactively prohibiting the acquisition of Jupiter Systems LLC, a Delaware limited liability company, by Suirui International Co. Ltd., a Hong...more
7/18/2025
/ Acquisitions ,
Business Assets ,
CFIUS ,
China ,
Cross-Border Transactions ,
Divestiture ,
Executive Orders ,
Foreign Investment ,
Hong Kong ,
Intangible Property ,
Intellectual Property Protection ,
National Security ,
Risk Assessment ,
Subsidiaries ,
Tangible Property ,
Technology Sector ,
Trump Administration
The Defense Counterintelligence and Security Agency (DCSA) published a press release on May 9, 2025, announcing an updated Standard Form 328 (SF-328), Certificate Pertaining to Foreign Interest. The updated form was approved...more
6/25/2025
/ Beneficial Owner ,
Defense Contracts ,
Department of Defense (DOD) ,
Disclosure Requirements ,
Federal Contractors ,
FOCI ,
Foreign Affiliates ,
Foreign Ownership ,
Government Agencies ,
National Security ,
Press Releases ,
Reporting Requirements ,
Required Forms ,
Risk Management
Nippon Steel Corp. and United States Steel Corp. published a press release on June 18, 2025, announcing the finalization of their merger agreement, executed on Dec. 18, 2023. Following a review by the Committee on Foreign...more
The U.S. Department of the Treasury on May 8, 2025, announced its intent to launch a fast-track process to facilitate greater investment from allied and partner sources. The process will include the launch of a "Known...more
5/14/2025
/ CFIUS ,
Executive Orders ,
Fast Track Process ,
Foreign Investment ,
International Trade ,
Investment ,
National Security ,
Pilot Programs ,
Portal ,
Trump Administration ,
U.S. Treasury
U.S. Department of Defense (DOD) contractors with foreign ownership, control, or influence (FOCI) soon will face new requirements. Though cleared DOD contractors have long been bound by FOCI obligations, the new rule will...more
4/24/2025
/ Beneficial Owner ,
Covered Entities ,
Defense Contracts ,
Defense Sector ,
Department of Defense (DOD) ,
DFARS ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Procurement Systems ,
Foreign Entities ,
Foreign Nationals ,
National Security ,
NDAA ,
Proposed Rules ,
Risk Mitigation ,
Subcontractors ,
Supply Chain
The U.S. Trade Representative (USTR) is seeking comments on the Trump Administration's "Fair and Reciprocal Plan" to assist it in identifying any unfair trade or non-reciprocal foreign trade practices. The deadline for...more
3/4/2025
/ America First Trade Policy ,
Antitrust Provisions ,
Comment Period ,
Imports ,
International Trade ,
National Security ,
Tariffs ,
Trade Deficit ,
Trade Relations ,
Trump Administration ,
US Trade Policies ,
USTR
President Donald Trump on Feb. 21, 2025, issued a National Security Presidential Memorandum (NSPM) titled "America First Investment Policy," outlining the administration's priorities regarding inbound and outbound...more
2/28/2025
/ America First Trade Policy ,
Artificial Intelligence ,
CFIUS ,
China ,
Executive Orders ,
Export Controls ,
Foreign Investment ,
National Security ,
Technology Sector ,
Trump Administration ,
U.S. Treasury
President Donald Trump issued a memorandum on reciprocal trade and tariffs on Feb. 13, 2025, citing the economic and national security threat posed by the trade deficit, as outlined in the Jan. 20, 2025, America First Trade...more
2/20/2025
/ America First Trade Policy ,
Executive Orders ,
Export Controls ,
International Trade ,
National Security ,
Presidential Memorandum ,
Tariffs ,
Trade Deficit ,
Trade Policy ,
Trade Relations ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies ,
USTR
President Donald Trump signed an executive order (EO) pausing all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least 180 days, along with directing the U.S. attorney...more
Through a presidential proclamation, the Trump Administration on Feb. 10, 2025, announced the reinstatement of a 25 percent tariff on all steel imports and an increase in aluminum tariffs from 10 percent to 25 percent. The...more
2/13/2025
/ Aluminum Sales ,
Foreign Policy ,
Imports ,
International Trade ,
National Security ,
Presidential Proclamations ,
Section 232 ,
Steel Industry ,
Tariffs ,
Trade Relations ,
Trump Administration ,
U.S. Commerce Department ,
USTR
President Donald Trump signed an Executive Order (EO) on Feb. 3, 2025, directing the Treasury and Commerce secretaries to submit a comprehensive plan within 90 days for the creation of the United States' first Sovereign...more
In the 17th episode of "Are We All Clear? Facilitating Security Clearances," host Molly O'Casey is joined by Antonia Tzinova, the head of Holland & Knight's Committee on Foreign Investment in the United States (CFIUS) and...more
Within hours after taking office on Jan. 20, 2025, U.S. President Donald Trump signed an omnibus executive order revoking 78 executive actions by the previous administration, dating back to 2021. Among them, President Trump...more
President Joe Biden on Jan. 3, 2025, issued a blocking order (the Order) addressing the proposed acquisition of United States Steel Corporation (U.S. Steel) by Nippon Steel Corporation (Nippon Steel), Japan's largest...more
1/21/2025
/ Acquisitions ,
Biden Administration ,
Blocking Power ,
CFIUS ,
Competition ,
Department of Justice (DOJ) ,
Foreign Investment ,
Mergers ,
National Security ,
Pending Litigation ,
Unions
In a much-anticipated decision, the U.S. Supreme Court on Jan. 17, 2025, rejected TikTok's appeal and upheld the Protecting Americans from Foreign Adversary Controlled Applications Act (Act). The act, which was signed into...more
1/20/2025
/ China ,
Constitutional Challenges ,
Data Privacy ,
Divestiture ,
Enforcement Actions ,
First Amendment ,
Foreign Investment ,
National Security ,
New Legislation ,
Parent Corporation ,
Regulatory Requirements ,
SCOTUS ,
Social Media ,
Social Networks ,
TikTok
Besides certain expansions on remittances in 2022, the White House, on Jan. 14, 2025, issued a statement announcing President Joe Biden's plans to relax sanctions on Cuba through a series of broad measures aimed at improving...more
1/17/2025
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Economic Sanctions ,
Export Controls ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
State Sponsors of Terrorism ,
Trump Administration ,
U.S. Treasury
The U.S. Department of the Treasury's Final Rule on outbound investment screening went into effect on Jan. 2, 2025. The Final Rule establishes a much-awaited outbound investment screening regime, implementing Executive Order...more
1/13/2025
/ Artificial Intelligence ,
Biden Administration ,
Compliance ,
Executive Orders ,
Export Controls ,
Final Rules ,
Foreign Investment ,
Investment ,
National Security ,
Outbound Transactions ,
Rulemaking Process ,
Semiconductors ,
Technology Sector ,
U.S. Treasury
In the latest episode of "Are We All Clear?", host Molly O'Casey and national security attorney Antonia Tzinova discuss Section 847 of the National Defense Authorization Act (NDAA), aimed at mitigating Foreign Ownership,...more
The U.S. Department of State's Directorate of Defense Trade Controls (DDTC) and U.S. Department of Commerce's Bureau of Industry and Security (BIS) on Oct. 23, 2024, published a set of three rules concerning space-related...more
12/2/2024
/ Bureau of Industry and Security (BIS) ,
Comment Period ,
Defense Sector ,
Directorate of Defense Trade Controls (DDTC) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
ITAR ,
National Security ,
Outer Space ,
Rulemaking Process ,
Time Extensions ,
U.S. Commerce Department ,
US State Departments
The 11th episode of "Are We All Clear? Facilitating Security Clearances" explores the role of outside directors and proxy holders within the National Industrial Security Program Operating Manual (NISPOM) framework and their...more
The U.S. Department of Commerce and U.S. Department of State have been continuously easing restrictions on export-controlled trade between the United States, United Kingdom and Australia to foster technological innovation...more
8/29/2024
/ Amended Rules ,
Artificial Intelligence ,
Australia ,
CFIUS ,
Comment Period ,
Cybersecurity ,
Defense Sector ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Innovative Technology ,
Interim Final Rules (IFR) ,
ITAR ,
Military Goods ,
National Security ,
Proposed Rules ,
U.S. Commerce Department ,
UK ,
US State Departments
In the ninth episode of "Are We All Clear? Facilitating Security Clearances," host Molly O'Casey and International Trade attorney Antonia Tzinova delve into the critical aspects of due diligence for facility and personnel...more
The U.S. Department of the Treasury's Office of Investment Security on June 21, 2024, issued a Notice of Proposed Rulemaking (Proposed Rule) implementing Executive Order (E.O.) 14105 that was announced on Aug. 9, 2023,...more
6/27/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
China ,
Comment Period ,
Executive Orders ,
Hong Kong ,
Macau ,
National Security ,
NPRM ,
Outbound Transactions ,
Technology Sector ,
U.S. Treasury
Almost six years after the enactment of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), the U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS),...more
5/13/2024
/ CFIUS ,
Covered Transactions ,
FIRRMA ,
Foreign Investment ,
National Security ,
Notice of Proposed Rulemaking (NOPR) ,
Penalties ,
Proposed Amendments ,
Proposed Rules ,
Request For Information ,
U.S. Treasury
The U.S. Government Accountability Office (GAO) published a report on Jan. 18, 2024, evaluating foreign investment in U.S. agricultural land. The report found that foreign investment in U.S. agricultural land grew to over 40...more