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Positive Development for Investors from Allied Nations - In a further solidification of the Administration’s efforts to isolate identified adversaries and strengthen U.S. leadership key strategic technologies, the...more
Welcome to this month’s issue of The BR International Trade Report, Blank Rome’s monthly digital newsletter highlighting international trade, sanctions, cross-border investment, geopolitical risk issues, trends, and laws...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
On February 21, 2025, President Trump issued a new memorandum addressing both foreign investment into the United States and outbound investment by US persons. Without imposing immediate legal or regulatory changes, the...more
With an array of unprecedented executive orders and other policies, the Trump administration’s “America First” trade strategy is beginning to take shape. As we monitor these developments, it is becoming increasingly clear...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
On Feb. 21, 2025, President Trump issued a National Security Presidential Memorandum (NSPM) introducing an “America First Investment Policy,” which sets the stage for a significant realignment of U.S. investment regulations....more
On January 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) that expands controls on advanced computing integrated circuits (ICs or chips) and model weights...more
U.S. investors interested in investing in advanced Chinese technology companies may now be constrained by the U.S. Government’s first-ever outbound investment rule (Final Rule) which took effect on Jan. 2, 2025. The Final...more
The incoming Trump administration is likely to continue the trend of strengthening export controls over AI and advanced semiconductors destined to China. During President-elect Donald Trump’s first term, the Bureau of...more
Broad Tariff Increases Could Reshape Global Trade: The aggressive use of tariffs could create significant trade disruptions for businesses dependent on global supply chains, and pair novel use of authorities with existing...more
As geopolitical tensions ratchet higher across the globe – fueled by the ongoing conflict in Ukraine, turbulent relations between China, the United States (US), and Europe, escalating conflict in the Middle East, and...more
August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more
The Committee on Foreign Investment in the United States (CFIUS) released its statutorily mandated annual report to congress last month. While the report itself highlights several notable developments in 2023 (New Zealand and...more
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
Melissa Duffy and Trevor Coval contributed their thought leadership to the American Conference Institute’s 14th Annual Global Encryption, Cloud & Cyber Export Controls Conference, held in San Francisco on May 14-16. Melissa...more
FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more
On December 12, the Select Committee on the Chinese Communist Party of the U.S. House of Representatives issued a comprehensive economic strategy containing over 160 policy recommendations intended to “to fundamentally reset...more
The economic relationship between China and the U.S. remains one of the most significant in the world, and U.S. and Chinese government leaders have repeatedly signaled their intent to maintain stable trade and commercial...more
Last week, the House Select Committee on the Strategic Competition between the United States and the Chinese Communist Party (Select Committee) issued a comprehensive new bipartisan report, including almost 150 policy...more
As the People’s Republic of China (PRC) has emerged as a major economic power and competitor, the U.S. has leaned heavily on and enhanced its foreign direct investment regime over recent years to protect its national security...more
A recent executive order issued by President Biden aims to prohibit or oversee investments in certain sensitive technologies that could threaten the national security of the United States. The executive order, which was...more
In recent years, the U.S. has pursued a whole-of-government approach to target Chinese technology and service providers in furtherance of foreign policy and national security objectives....more
On August 9, 2023, President Biden issued an Executive Order (E.O.) ordering the issuance of outbound investment restrictions. This E.O. comes after nearly a year of anticipation (as we have documented on several occasions...more
On August 9, President Biden issued an executive order (E.O.) directing the U.S. Department of the Treasury (Treasury), in consultation with the U.S. Department of Commerce and other U.S. agencies, to adopt regulations that...more