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A New Era of FCPA Enforcement

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memorandum”) detailing new guidelines for the Department of Justice’s approach to investigating and enforcing the Foreign Corrupt...more

Biden Administration’s Eleventh-Hour Executive Order Imposes New Software Requirements on Companies

On January 16, 2025, President Biden issued Executive Order 14144 on Strengthening and Promoting Innovation in the Nation’s Cybersecurity (the “EO”). Building on prior initiatives such as Executive Order 14028 and the...more

New Data Center Validated End User Program Creates Pathway to Export Advanced U.S. Technology; Rigorous Review and Vetting...

Effective October 2, 2024, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), amended the Export Administration Regulations (EAR), 15 C.F.R. Parts 730 – 774, to expand the Validated End User (VEU)...more

Department of Treasury Issues Proposed Rule Covering Outbound Investments

Regulations ultimately will implement a new program restricting certain investments related to China- On June 21, 2024, the U.S. Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (the “Rule”)...more

FBI and DOJ Offer Guidance on SEC Cybersecurity Incident Disclosure Rules

On December 18, 2023, new cybersecurity rules adopted by the U.S. Securities and Exchange Commission (SEC) became effective. Among other things, those rules require SEC registrants to disclose certain information about...more

Executive Order Establishes New Outbound Investment Screening Program

Prohibitions targeted to prevent China’s exploitation of dual-use technology - On August 9, 2023, President Biden signed a historic Executive Order on Addressing United States Investments in Certain National Security...more

Heightened Focus on Foreign Influence in Academia

Department of Education Report Warns that Academic Institutions Are Failing to Meet Compliance Obligations in Fight Against Foreign Influence Last month the Department of Education (“DOE” or “Department”) released an...more

Virtual Currency as a Threat to National Security?

In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

CFIUS Finalizes Rules Reforming Foreign Investment Reviews

On February 13, 2020, two Final Rules issued by the Committee on Foreign Investment in the United States’ (“CFIUS”) implementing most of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”) became...more

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