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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 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more
The Department of Treasury announced a forthcoming Fast Track Pilot Program where foreign investors can register to streamline compliance with the Committee on Foreign Investment in the United States (CFIUS). The goal of the...more
On May 8, 2025, the U.S. Department of the Treasury (Treasury) announced that it will create a “fast-track pilot program” for certain foreign investors. The stated goal of the program is to streamline investment reviews by...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
On May 8, 2025, the U.S. Department of the Treasury, which leads the interagency Committee on Foreign Investment in the United States (CFIUS), announced plans to establish a fast-track process for foreign investors, including...more
Key takeaways U.S. Treasury to establish a “fast track” foreign investment review process. It will include a “Known Investor” portal that allows the submission of information in advance of filing with Committee on Foreign...more
The U.S. Department of the Treasury on May 8, 2025, announced its intent to launch a fast-track process to facilitate greater investment from allied and partner sources. The process will include the launch of a "Known...more
On May 8, 2025, the U.S. Treasury Department announced its intent to launch a Fast Track Pilot Program designed to streamline the Committee on Foreign Investment in the United States ("CFIUS") review process for certain...more
In its FAQs, U.S. Custom and Border Protection (CBP) clarified the exemption from reciprocal tariffs for goods subject to steel/aluminum Section 232 duties under HTSUS 9903.01.33. CBP clarified that the exemption only applies...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
As geopolitical tensions rise and the post-Cold War global order continues to fray, national security has experienced a renewed policymaking focus. The most prominent areas in this regard have been critical technology...more