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In May 2025, the Treasury Department, as chair of the Committee on Foreign Investment in the United States (CFIUS), announced a new “fast track process to facilitate greater investment in U.S. businesses from ally and partner...more
On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more
The U.S. Department of the Treasury (“Treasury”) has been active in the context of the Committee on Foreign Investment in the United States’ (“CFIUS”) and the Outbound Investment Security Program (“OISP”). The main updates...more
On May 8, the Treasury Department announced a plan to introduce a new Known Investor portal as a key component of the “fast-track” process for investments by U.S. allies and partners under review by the Committee on Foreign...more
On May 8, 2025, the U.S. Department of the Treasury (Treasury) announced plans to establish a “fast-track” review process for the Committee on Foreign Investment in the United States (CFIUS). This initiative implements a key...more
Potential policy changes could offer opportunities for CFIUS filers in low-risk transactions while introducing added challenges for transaction parties linked to sensitive countries....more
On February 21, 2025, President Trump issued a memorandum titled "America First Investment Policy" (the “Policy”), outlining new measures to shape U.S. investment policy. Though the Policy makes it clear that the United...more
This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more
On February 21, 2025, the White House released a memorandum titled, “America First Investment Policy” (the Memorandum). The Memorandum describes how this Administration plans to address U.S. national security risks stemming...more
Below is a summary of some of the measures identified in the Policy, and some suggestions for what foreign and domestic investors should be considering as this goes into effect....more
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
On February 21, 2025, President Trump issued a National Security Presidential Memorandum titled “America First Investment Policy,” outlining several key strategies aimed at enhancing U.S. national and economic security...more
On February 21, President Trump issued the “America First Investment Policy” National Security Presidential Memorandum (“NSPM”) which outlines the Administration’s approach to foreign investment in the United States. The NSPM...more
On February 21, 2025, President Trump issued the America First Investment Policy Memorandum, which emphasizes the U.S. commitment to a strong, open investment environment while reshaping the U.S. government’s policy towards...more
Foreign Ownership, Control, or Influence (FOCI) refers to a situation where a foreign entity has the power to directly or indirectly influence the management or operations of a company. FOCI can result from legal means like...more
On February 21, 2025, President Trump signed a National Security Presidential Memorandum (NSPM) announcing an “America First Investment Policy” focused on promoting foreign investment in the United States from allies and...more
On February 21, 2025, a Presidential Memorandum, “America First Investment Policy” (the “Memorandum”), announced planned changes to the Committee on Foreign Investment in the United States (“CFIUS”) and outbound investment...more
New U.S. investment and export control measures are shaping how businesses engage with foreign markets, particularly China. From limiting outbound investments to tightening export licenses, these evolving policies from the...more
The policy memo aims to preserve an open investment environment as well as restrict investment in strategic sectors. Late on Friday, February 21, 2025, the White House released its “America First Investment Policy”...more
Navigating the complex landscape of foreign investment review is crucial for private equity (PE) firms operating in an international landscape. The Committee on Foreign Investment in the United States (CFIUS) continues to be...more
Effective in January 2025, the U.S. Department of the Treasury issued a final rule (colloquially known as “Reverse CFIUS”) implementing the Outbound Investment Program, which prohibits U.S. persons from making certain...more
U.S. law has long subjected foreign investments into the U.S. to review and restriction by the Committee on Foreign Investment in the United States (“CFIUS”), but outside of economic sanctions programs, has typically not...more
As we head toward Valentine’s Day 2025, everywhere you look, love is all around. Washington, D.C., is no exception—the White House and government agencies seem to be proudly displaying their ardor for changing the country’s...more
On August 9, 2023, former-President Biden issued Executive Order 14105, Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern, which in summary directed the U.S....more
Tandis que la future administration Trump se prépare à prendre ses fonctions, de nombreuses évolutions, tant au niveau réglementaire qu’en matière de mise en œuvre des règlementations par les autorités américaines compétentes...more