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Wiley Rein LLP

CFIUS 2024 Annual Report: Compliance, Enforcement, and Non‑Notified Transactions – What Dealmakers Need to Know

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The Committee on Foreign Investment in the United States (CFIUS) recently released the public version of its Annual Report to Congress for calendar year 2024. Key trends include an increase in formal inquiries into...more

Wiley Rein LLP

FTC Consumer Protection and Privacy Enforcement Series: PADFA Enforcement—What Companies Need to Know

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As part of our series to provide practical insights into emerging Federal Trade Commission (FTC) priority areas for consumer protection and data privacy enforcement, we are taking a deep dive into the Protecting Americans’...more

Carlton Fields

No Password Required: Former Lead Attorney at U.S. Cyber Command, Cyber Law Strategist, and Appreciator of ‘Mad Men’ Hats

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On this episode, hosts Jack Clabby of Carlton Fields and Kayley Melton, executive director of operations at the Cognitive Security Institute, sit down with Kurt Sanger — a seasoned cyber law leader and former deputy general...more

Husch Blackwell LLP

Trump Administration’s AI Action Plan and New Executive Orders Offer Strategic Opportunities and Legal Risks for Private...

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Key Point: “Winning the Race: America’s AI Action Plan,” the Trump Administration’s summary approach to federal artificial intelligence (AI) policy, and three new Executive Orders (EO) propose a wide-ranging federal strategy...more

Morrison & Foerster LLP

FTC Looks to Leverage PADFAA Enforcement to Help Limit Exposure of Consumer Data

In recent comments, Commissioner Holyoak signaled that the Federal Trade Commission will prioritize enforcement of the Protecting Americans’ Data from Foreign Adversaries Act (PADFAA), a law that empowers the FTC to police...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for June 2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Ropes & Gray LLP

AI and Tech under the One Big Beautiful Bill Act: Key Restrictions, Risks, and Opportunities

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On July 4, 2025, President Trump signed “The One Big Beautiful Bill Act” into law. While much attention has focused on the bill’s rejection of a proposed 10-year federal ban on state and local artificial intelligence (“AI”)...more

Arnall Golden Gregory LLP

From Private Company to Government Contractor Overnight: How the Defense Production Act Can Transform Your Business Without...

The Defense Production Act of 1950 (“DPA”) remains one of the most powerful yet underutilized tools in the federal government’s arsenal for mobilizing private industry during national emergencies. For in-house counsel,...more

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

Jenner & Block

Client Alert: Myth Busters: Dispelling Common Misconceptions of the Department of Justice’s Data Security Program

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A month has passed since the Department of Justice (DOJ) National Security Division’s (NSD) issued its Final Rule prohibiting certain transactions involving US government data and Americans’ bulk sensitive personal data....more

WilmerHale

Voluntary Disclosure of Export Control Violations is Critical for Settling Criminal Liability, DOJ Action Shows

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The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more

Thomas Fox - Compliance Evangelist

Regulatory Ramblings: Episode 68 - Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen

The hasty U.S. withdrawal from Afghanistan in August 2021 under the Biden administration—and the fallout that followed—along with the Russian invasion of Ukraine in February 2022 and the ongoing war, have created inflationary...more

Paul Hastings LLP

The UK Launches Its Own ‘FARA’: What Companies Need to Know About the New Foreign Influence Registration Scheme

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On July 1, 2025, the United Kingdom’s new Foreign Influence Registration Scheme (FIRS) will formally take effect, creating sweeping registration obligations under U.K. law for persons engaging in certain activities on behalf...more

Snell & Wilmer

Reevaluating the Foreign Corrupt Practices Act Enforcement: A New Paradigm

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On February 10, 2025, President Trump signed an Executive Order (E.O.) directing a shift in the enforcement of the Foreign Corrupt Practices Act (FCPA). The order effectively pauses new FCPA investigations and enforcement...more

Ropes & Gray LLP

Enforcement under the Trump Administration: Reports of the FCPA’s Death are Exaggerated

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On February 10, 2025, President Trump issued an executive order (the “EO”) directing the U.S. Department of Justice (“DOJ”) to pause new Foreign Corrupt Practices Act (“FCPA”) investigations and enforcement actions for 180...more

Snell & Wilmer

Hitting the Ground Running: Trump’s Promised Tariffs on February 1, 2025

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As President Trump begins his second term, the absence of tariffs among the more than 200 executive orders signed on his first day in office was a notable deviation from expectations. However, the President announced plans to...more

Venable LLP

A Stronger CFIUS: Final Rules Issued Expanding Mitigation and Enforcement Powers

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On November 18, 2024, the U.S. Department of the Treasury issued a final rule enhancing the mitigation monitoring and enforcement tools of the Committee on Foreign Investment in the United States (CFIUS or the "Committee")....more

WilmerHale

Biden Administration Finalizes Controls on U.S. Investment in China

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On October 28, the Biden Administration released its long-awaited final rule to restrict U.S. investment in China. This outbound investment regime, which is effective January 2, 2025, will impact all U.S. companies and...more

Wilson Sonsini Goodrich & Rosati

National Security Division’s Voluntary Self-Disclosure Policy in Action: Exchanging Cooperation for Declination

Last month, the U.S. Department of Justice (DOJ) announced that it would not charge MilliporeSigma, a life sciences company, even though one of its employees falsified export documents. The DOJ declined to prosecute...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

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On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Ankura

CFIUS Issues Enforcement and Penalty Guidelines Intended to Drive Compliance with FDI Reviews and Mitigation

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On October 20, 2022, the Committee on Foreign Investment in the United States (CFIUS) issued new Enforcement and Penalty Guidelines (the “Guidelines”). CFIUS is an interagency committee that reviews and seeks to mitigate...more

Dorsey & Whitney LLP

CFIUS Annual Report - A Banner Year for Filings and Inquiries to Parties of Non-Notified Transactions

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The Committee on Foreign Investment in the United States (“CFIUS”) released its much-anticipated Calendar Year 2021 Annual Report that provides useful insights into how CFIUS operates, the types of transactions it is...more

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

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In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

Morrison & Foerster LLP

OFAC Has Been Talking About Compliance Through Enforcement - Have You Been Listening?

Last Thursday, January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued its first enforcement action of 2019, a fascinating case involving false eyelashes that teaches that virtually any...more

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