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CFIUS Non-Notified Transaction Enforcement: Cooley’s Five-Year Lookback

March 2025 marked the fifth anniversary of the Committee on Foreign Investment in the United States (CFIUS) initiative to “formalize and centralize” within the Department of the Treasury an enforcement function to identify...more

US Outbound Investment Enforcement Is Now Live

Despite uncertainty amid talks of reforming the Outbound Investment Security Program (OISP), the US Department of the Treasury is already actively pursuing enforcement actions against transaction parties that may have...more

The America First Investment Policy

On February 21, 2025, the White House issued a memorandum announcing the America First Investment Policy (AFIP) and directing executive branch departments and agencies to promulgate rules and regulations to promote America’s...more

Assessing the Impact of the Outbound Investment Security Program on Debt Transactions

On January 2, 2025, the US Department of the Treasury implemented the new Outbound Investment Security Program (OISP), which prohibits or imposes notification requirements on certain investments by US persons in persons that...more

Outbound Investment Security Program: Final Rule

On October 28, 2024, the US Department of the Treasury issued final regulations implementing the Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of...more

As CFIUS Announces Significant Penalties, Companies and Investors Confront a Shift in CFIUS Filing Cost-Benefit Dynamics

On the heels of releasing its 2023 Annual Report to Congress, the Committee on Foreign Investment in the United States (CFIUS) publicly announced six new penalties on parties that failed to comply with CFIUS requirements in...more

SBA May Eliminate Self-Certification of SDVOSB Status for Federal Contracting

On June 6, 2024, the US Small Business Administration (SBA) published a direct final rule that would eliminate self-certification of service-disabled veteran-owned small businesses (SDVOSB) status for purposes of agency...more

Cooley’s 2023 Tech M&A Year in Review: An AI-Generated Glass Half Full

2023’s much-discussed downturn in mergers & acquisitions – with global M&A volume and value down 6% and 17%, respectively, from 2022 – was largely driven by the slowdown in the tech sector, with global tech M&A volumes down...more

Court of Justice Sets Lightning Rod for EU Foreign Direct Investment Screening

On 13 July 2023, the Court of Justice of the European Union (CJEU) handed down its first ruling on the European Union Foreign Direct Investment Screening Regulation, which entered into force in October 2020. In short, the...more

Alert: US Government Imposes Export Restrictions on SMIC, DJI and 75 Other Entities

The US Department of Commerce’s Bureau of Industry and Security has issued a Final Rule adding 77 companies to the Entity List, a restricted party list that identifies foreign persons that engage in activities contrary to US...more

Alert: DoD’s New Cybersecurity Rules Take Effect November 30

The Department of Defense’s interim rule implementing new cybersecurity requirements for government defense contractors is set to take effect on November 30, 2020. Published on September 29, 2020, the rule establishes a...more

Alert: CFIUS Final Rule Leverages Export Control Principles to Redefine Mandatory Filing Requirements

On September 15, 2020, the US Department of the Treasury issued a Final Rule comprising the latest regulation in an ongoing effort to reform the way the United States reviews and confronts the national security implications...more

Alert: Impact of COVID-19 on Global Foreign Direct Investment Screening Mechanisms

Governments across the globe have been tightening up efforts to screen foreign investments by implementing legislation to protect their own national interests and economies. This has become ever more apparent during the...more

Alert: New PPP Loan FAQ: Safe Harbor Extended to May 14, 2020

A key aspect of the CARES Act relief package is the now-well-known Paycheck Protection Program (PPP) administered by the Small Business Administration (SBA). ...more

Alert: CFIUS Filing Fees Become Effective on May 1

When Congress passed the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) to strengthen and expand the jurisdictional reach of the Committee on Foreign Investment in the United States, (CFIUS) we knew that...more

Alert: SBA PPP Loans – Calculations and Considerations for Maximizing Forgiveness

Loan forgiveness is a key feature of the Paycheck Protection Program (PPP) administered by the Small Business Administration (SBA) pursuant to the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). If PPP loan...more

Alert: Help for Government Contractors Dealing with COVID-19 – CARES Act Section 3610 Ensuring Ready State

While much of the focus of the recently enacted CARES Act has been on providing loans and grants to help small businesses meet payroll and avoid layoffs, Section 3610 of the CARES Act provides critical support specifically to...more

Alert: SBA Programs Under the CARES Act: ‘Affiliation’ Interim Final Rules and Guidance

A key feature of the CARES Act $2 trillion relief package is the creation of the Paycheck Protection Program (PPP), which authorizes $349 billion for businesses to obtain loans of up to $10 million per applicant to be used on...more

Alert: SBA Programs Under the CARES Act: Loan Application and Information Sheet Issued

A key feature of the CARES Act $2 trillion relief package is the creation of the Paycheck Protection Program (PPP), which authorizes $349 billion for businesses to obtain loans of up to $10 million per applicant to be used on...more

Alert: President Signs CARES Act

The President has signed a $2 trillion relief package, the "Coronavirus Aid, Relief, and Economic Security Act" (CARES Act). The CARES Act is intended to provide "emergency assistance and health care response for individuals,...more

Alert: Trump Invokes Defense Production Act to Surge Industrial Capacity

On Wednesday, March 18, 2020, President Trump issued an executive order invoking Section 101 of the Defense Production Act of 1950 in an effort to "surge capacity and capability to respond to the spread of COVID-19."...more

Alert: CFIUS Introduces Filing Fees

In a sweeping change, the Committee on Foreign Investment in the United States will soon require parties to transactions to pay filing fees in connection with certain CFIUS filings. Under the proposed rule published in the...more

Alert: DoD to Require Contractors to be Cyber-Certified by Fall 2020

On January 31, 2020, the Department of Defense released Version 1.0 of its Cybersecurity Maturity Model Certification for defense contractors. The model is intended to incorporate and build upon existing cybersecurity...more

Alert: CFIUS Update: Final Regulations Implement FIRRMA

The US Department of the Treasury has issued two final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA"). The final regulations broadly expand the jurisdiction of the Committee...more

Blog: Cooley’s 2019 Tech M&A Year in Review

In the wake of record-setting volume and value metrics in 2018, practitioners eyed the 2019 deal market with healthy skepticism. Despite a slight downward tick in momentum and overall deal statistics, 2019 remained a robust,...more

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