On May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more
6/12/2025
/ Bureau of Industry and Security (BIS) ,
CAATSA ,
CFIUS ,
Economic Sanctions ,
EU ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Reform ,
SDN List ,
Syria ,
Trump Administration ,
U.S. Treasury ,
UK
Following years of development, on October 28, 2024, the U.S. Department of the Treasury published a final rule establishing its outbound investment security program (Final Rule). The new regime prohibits certain outbound...more
10/31/2024
/ Artificial Intelligence ,
China ,
Executive Authority ,
Final Rules ,
Foreign Investment ,
Foreign Persons ,
Information Technology ,
Lawful Permanent Residents ,
National Security ,
Semiconductors ,
U.S. Treasury
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
7/11/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
CFIUS ,
China ,
Covered Transactions ,
Due Diligence ,
Equity Investors ,
Foreign Nationals ,
Information Technology ,
International Emergency Economic Powers Act (IEEPA) ,
Investment ,
Popular ,
Screening Procedures ,
U.S. Treasury
On April 11, 2024, the Committee on Foreign Investment in the United States (CFIUS) unveiled updates to its regulations that sharpen CFIUS’s processes and enforcement authorities. Together with remarks by U.S. government...more
On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more
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
12/15/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
China ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Foreign Investment ,
Foreign Nationals ,
Investment ,
Semiconductors ,
Technology ,
U.S. Treasury
As close observers of the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) are aware, the Committee has the authority to recommend that the President of the United States block a transaction on...more
On March 12, 2021, a U.S. district court granted a temporary injunction requested by the Hong Kong-listed, Chinese electronics giant, Xiaomi Corporation (“Xiaomi”). The injunction blocks the U.S. Department of Defense (“DoD”)...more
3/22/2021
/ Biden Administration ,
Department of Defense (DOD) ,
Executive Orders ,
Hong Kong ,
Injunctions ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Preliminary Injunctions ,
Prohibited Transactions ,
Regulatory Authority ,
Sanctions ,
SDN List ,
Technology Sector ,
Trump Administration ,
U.S. Treasury
Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more
Parties to investment transactions involving U.S. businesses engaged in “critical technologies” activities will soon be subject to modified requirements for mandatory filings to the Committee on Foreign Investment in the...more
9/18/2020
/ CFIUS ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
FIRRMA ,
Foreign Investment ,
ITAR ,
NAICS ,
National Security ,
U.S. Commerce Department ,
U.S. Treasury
The U.S. Department of the Treasury (“Treasury”) announced that on Friday, May 1, 2020, the first-ever filing fees will become effective for joint voluntary notices submitted to the Committee on Foreign Investment in the...more
On February 18, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading S.A. (“Rosneft Trading”) and its president to the agency’s List of Specially Designated Nationals and...more
The U.S. Department of the Treasury (Treasury) has released final regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA), expanding the jurisdiction of the Committee on Foreign Investment in...more
This is the third in our multipart series of alerts addressing proposed regulations published in the Federal Register on September 24, 2019, for the Committee on Foreign Investment in the United States (CFIUS) to implement...more
After more than a year of anticipation, the U.S. Department of the Treasury (“Treasury”) has released proposed regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA). These proposed regulations...more
After more than a year of anticipation, the U.S. Department of the Treasury (“Treasury”) has released proposed regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA). These proposed regulations...more
As many life sciences companies and investors are aware, the U.S. Department of the Treasury (“Treasury”) recently announced a new “pilot program” for the Committee on Foreign Investment in the United States (“CFIUS”)...more
As many life sciences companies and investors are aware, the U.S. Department of the Treasury (“Treasury”) recently announced a new “pilot program” for the Committee on Foreign Investment in the United States (“CFIUS”)...more