FCPA Compliance Report – Episode 732 – Understanding Anti-Boycott Compliance with Alexander Cotoia
ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of...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
The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...more
On June 20, the Department of Commerce’s Bureau of Industry and Security (BIS) for the first time banned a software and cybersecurity company using authority provided by June 2023’s “Protecting Americans’ Sensitive Data from...more
On April 15, the U.S. Department of the Treasury published a proposed rule that would enhance certain Committee on Foreign Investment in the United States (CFIUS or the Committee) procedures and increase CFIUS penalty and...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
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
1. Updates to Russia Sanctions and Export Controls- In response to the ongoing attack on Ukraine, the U.S. government continues on a weekly basis to increase economic sanctions and export controls on Russia. ...more
Last week, the U.S. Government imposed tough restrictions on U.S. transactions with specific companies in the People’s Republic of China (PRC) that are involved in activities contrary to U.S. foreign policy and national...more
On October 28, 2021, a bipartisan group of U.S. Senators introduced the Food Security is National Security Act of 2021 (the “Act”). Among other things, the Act would require the Committee on Foreign Investment in the United...more
In his last days, President Trump takes a swipe against companies identified by the Department of Defense (DoD) as Communist Chinese military companies by prohibiting US persons from investments. On November 12, 2020,...more
Parties to investment transactions involving U.S. businesses engaged in “critical technologies” activities will soon be subject to modified requirements for mandatory filings to the Committee on Foreign Investment in the...more
The Situation: The U.S. Department of the Treasury ("Treasury Department") recently issued proposed regulations that will alter and in some cases expand the scope of critical technology foreign investments subject to...more
With strengthened legislative mandates and significant regulatory reform in place, the U.S. government’s national security focus on protecting sensitive technology and data continues to gather steam. Although exactly what...more
The U.S. Treasury Department, on behalf of the Committee on Foreign Investment in the United States (CFIUS) issued two final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA),...more
The Situation: The U.S. Department of the Treasury ("Treasury Department") released final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA"), which, among other things, effectuate...more
The Department of Treasury has released the final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”), which contain significant changes to the process by which the Committee on...more
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
On January 13, 2020, the U.S. Department of Treasury issued final regulations (the "Final Rules") that implement most of the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA"). While the Final Rules provide...more
ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
On Oct. 10, 2018, the U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS or the Committee), issued interim regulations (the Regulations) setting forth the scope of,...more
A little more than two months after the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”) was signed into law, the United States Department of the Treasury (has invoked its new authority under the FIRRMA to...more