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Senate Eyes New Role for CFIUS in Combating ‘Foreign Malign Influence or Espionage Activities’ Targeting ‘Institutions of Higher...

This potential expansion of CFIUS’s powers suggests broader congressional concern about attempts by Chinese entities to circumvent CFIUS reviews and access critical technologies. New legislation may soon expand the...more

CFIUS 2.0: Mandatory Filings Now Pegged to Export Control Rules

The Committee on Foreign Investment in the United States (CFIUS) is now following new rules on mandatory filings for certain foreign investments in critical technology companies. As a refresher, CFIUS is the US Government’s...more

Commerce Launches Rulemaking Process on Foundational Technologies, Hints at Three Potential Areas of Control

BIS will be looking at items that are controlled only for anti-terrorism, crime control, short supply, United Nations embargoes, or designated as EAR99 in establishing new Foundational Technologies Controls. Two years...more

Huawei Rule Part 2: You “Use,” You Lose (Government Contracts)

The new regulations prohibit government agencies from entering into, extending, or renewing a contract with contractors if they use any equipment, system, or service that uses certain Chinese telecommunications equipment or...more

CFIUS 2.0: Treasury Unveils Final Regulations to Govern Expanded Foreign Investment Screening

On January 13, 2020, the Treasury Department, on behalf of the full Committee on Foreign Investment in the United States (CFIUS), released the comprehensive final regulations to implement the Foreign Investment Risk Review...more

US Issues First Unilateral Export Control on Artificial Intelligence Software

This software now requires a BIS authorization to be exported or reexported to all countries except for Canada. Companies that develop or use artificial intelligence (AI) to solve geospatial problems or in geospatial...more

CFIUS 2.0: Emerging Tech Minority Investments – Expansion of Jurisdictional Scope Remains in Limbo

In FIRRMA and ECRA, Congress essentially gave Commerce authority to decide how narrowly or widely to set the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) over non-passive minority...more

CFIUS 2.0: Treasury Releases Comprehensive Rewrite of CFIUS Regulations, Flood of Filings Expected in 2020

On September 17, 2019, the Treasury Department, on behalf of the full Committee on Foreign Investment in the United States, released the long-awaited comprehensive draft regulations to implement the Foreign Investment Risk...more

CFIUS 2.0: Real Estate as a Platform for Foreign Espionage Against the US Government?

The Committee on Foreign Investment in the United States (CFIUS) is an interagency federal body that screens inbound foreign investments for national security risks, and it is currently putting the finishing touches on its...more

CFIUS 2.0: ‘Sensitive Personal Data’ in the National Security Context

In recent years, the Committee on Foreign Investment in the United States (CFIUS) has taken a much stronger interest in the national security ramifications of sensitive data falling into the hands of foreign adversaries,...more

New Huawei Rule: What it Means for US Companies

In another blow to Huawei, on August 7, 2019, the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) issued an interim rule amending the Federal...more

CFIUS 2.0: Key CFIUS Leader at Treasury Likely Sworn in by Mid-September, Draft Regulations Still Looming

The US Senate is poised to confirm Tom Feddo to run CFIUS as Assistant Secretary of the Treasury for Investment Security, increasing the bandwidth of CFIUS at a critical time in its history....more

CFIUS 2.0: Investment Funds and Other Stakeholders Await Full, Revamped Regulations

In August of last year, President Trump signed into law the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), a sweeping overhaul of the operations and jurisdiction of the Committee on Foreign Investment in...more

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