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Civil Monetary Penalty National Security

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First-Ever Monetary Penalty for a Failure To Provide Information: Key Considerations for Companies

The Offence and Penalty - On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more

Hogan Lovells

U.S. Treasury expands the scope of CFIUS investigative authority and updates civil monetary penalties

Hogan Lovells on

On November 26, 2024, the U.S. Department of the Treasury (“Treasury”) issued a new final rule (the “Final Rule”) expanding the Committee on Foreign Investment in the United States’ (“CFIUS”) authority in three key areas...more

The Volkov Law Group

DDTC Fines Precision Castparts Corp. $3 Million for AECA and ITAR Violations

The Volkov Law Group on

In a significant enforcement action, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) has charged Oregon-based Precision Castparts Corp. (“PCC”) with multiple violations of the Arms Export Control...more

Jones Day

CFIUS Annual Report Touts an Increase in Penalties and Efficiency in Transaction Reviews

Jones Day on

While the total number of filings declined in comparison to recent years, CFIUS's latest Annual Report to Congress highlights an uptick in penalties and an increased use of enforcement tools relating to national...more

Mayer Brown

CFIUS Announces $60 Million Penalty and Debuts New Enforcement Website

Mayer Brown on

On August 14, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) announced a $60 million penalty, “the largest penalty CFIUS has ever issued,” following its finding of material violations...more

Mintz

Three Key Takeaways from CFIUS's 2023 Annual Report

Mintz on

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

K&L Gates LLP

US Treasury Department Moves Closer to Implementing Outbound Investment Restrictions Through Latest Proposed Regulations

K&L Gates LLP on

On 21 June 2024, the Office of Investment Security of the US Department of the Treasury (Treasury) issued proposed regulations to implement President Biden’s August 2023 Executive Order on Addressing United States Investments...more

Cadwalader, Wickersham & Taft LLP

Treasury Proposes Enhancing CFIUS Enforcement Authority

On April 11, 2024, the U.S. Department of the Treasury announced a notice of proposed rulemaking that would expand the enforcement authority of the Committee on Foreign Investment in the United States (“CFIUS” or the...more

Stikeman Elliott LLP

New Public Register Proposed for Advocates of Foreign State-Owned and Controlled Enterprises

Stikeman Elliott LLP on

As part of a new bill intended to combat foreign interference in Canadian affairs, the Canadian government has proposed that any person advocating for certain types of foreign actors with respect to activities intended to...more

Pillsbury Winthrop Shaw Pittman LLP

U.S. Passes Social Media and Data Broker Bills Targeting Data Use Practices

As part of the national security supplemental package, President Biden has signed into law two provisions targeting data use practices by websites, desktop applications, mobile apps, and augmented or immersive technology...more

Alston & Bird

Treasury to Sharpen CFIUS Procedures and Enforcement

Alston & Bird on

Proposed changes to how the Committee on Foreign Investment in the United States (CFIUS) can request information and impose civil penalties signal that CFIUS will increasingly focus on compliance and enforcement. Our...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFIUS’ Proposed Rule: More Questions, Tighter Time Frames and Higher Penalties

On April 15, 2024, the secretary of the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS or Committee), published a notice of proposed rulemaking (Proposed Rule) to...more

Sheppard Mullin Richter & Hampton LLP

Treasury Department Proposes to Sharpen the Teeth of CFIUS Enforcement

Key Takeaways: The Treasury Department is seeking to equip CFIUS with greater enforcement and oversight authority. These new powers include the ability to request more information from transaction parties and also to assess...more

Akerman LLP

Treasury Proposes Enhancements to CFIUS Procedures, Penalties, and Enforcement Authority

Akerman LLP on

On April 11, 2024, the U.S. Department of the Treasury issued a Notice of Proposed Rulemaking (NPRM) proposing a new rule updating the mitigation and enforcement provisions of the regulations administered by the Committee on...more

White & Case LLP

CFIUS Proposes Regulatory Updates to Shorten Mitigation Negotiation Timelines for Transaction Parties & Expand CFIUS Authorities...

White & Case LLP on

On April 11th, the US Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM) to "enhance certain CFIUS procedures and sharpen...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

Seward & Kissel LLP on

The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Warner Norcross + Judd

New Corporate Transparency Act Reporting Requirement Begins in 2024

Warner Norcross + Judd on

Starting in 2024, all “reporting companies,” meaning any entity formed by filing with a secretary of state or similar office, will be required to file a “beneficial ownership report” with the U.S. Treasury Department’s...more

Saiber LLC

The Corporate Transparency Act: Are You Prepared?

Saiber LLC on

Beginning on January 1, 2024, millions of business entities (including corporations, limited liability companies, and other similar entities created in or registered to do business in the United States) will be required to...more

Torres Trade Law, PLLC

Five Key Takeaways from the 2023 CFIUS Conference

Torres Trade Law, PLLC on

On September 14, 2023, the U.S. Department of the Treasury held the annual Committee on Foreign Investment in the United States (“CFIUS”) Conference in Washington, DC. The interagency Committee is tasked with reviewing...more

Dorsey & Whitney LLP

Executive Order 14105 on Outbound Investment in China and Proposed Rule

Dorsey & Whitney LLP on

On August 9, President Biden issued Executive Order 14105 (“EO 14105”) on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. EO 14105 significantly reshapes...more

Fenwick & West LLP

Defense Trade Controls: State and Commerce Departments Begin 2023 with Regulatory Focus on Defense Services and Other Updates

Fenwick & West LLP on

The U.S. Department of State (State Department) and U.S. Department of Commerce (Commerce Department), have recently previewed, proposed or finalized changes to relevant trade controls. These new regulatory updates include...more

White & Case LLP

CFIUS Issues New Enforcement and Penalty Guidelines

White & Case LLP on

On October 20, 2022, the US Department of the Treasury, as Chair of the Committee on Foreign Investment in the United States (CFIUS), released the first-ever CFIUS Enforcement and Penalty Guidelines (Guidelines). The...more

The Volkov Law Group

DC Circuit Court Rejects Federal Express Challenge to Civil Liability for Violations of Export Regulations

The Volkov Law Group on

The D.C Circuit Court of Appeals sits in a unique position as the primary reviewing court for federal government agency actions.  As a result, the D.C. Circuit sits in a high-profile position and several judges have...more

White & Case LLP

Foreign direct investment reviews 2021: Australia

White & Case LLP on

Australia requires a wide variety of investments by foreign businesses to be reviewed and approved - Some significant investment proposals have been rejected on national interest grounds since 2020 - The decision to...more

Eversheds Sutherland (US) LLP

Update on recent US sanctions developments - Nord Stream 2 sanctions and Exxon Mobil decision

This briefing is intended to provide an update on two recent developments under the US sanctions regime. ..The first one is the introduction of US sanctions related to the Nord Stream 2 pipeline project, which threaten to...more

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