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The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more
With bitcoin hitting its all-time high of $112,000 in May 2025, and President Trump’s ongoing vocal support for cryptocurrency, it is worth examining the establishment of a strategic digital asset reserve. Executive Order...more
The U.S. Department of the Treasury has started enforcing final regulations that restrict, and in some cases prohibit, U.S. companies, funds and individuals from making certain investments in some technology industries owned...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
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
Introduction - On 28 October 2024, the US Treasury Department issued a Final Rule implementing the Outbound Investment Program (OIP) under Executive Order 14105, which safeguards US national security by limiting investments...more
The Final Rule formalizes a new governmental system to monitor through a notification process and, when necessary, restrict investments in China that may be viewed as a national security risk. The regulations have broad...more
On 28 October 2024, the U.S. Department of the Treasury (Treasury) issued the Provisions Pertaining to U.S. Investments in Certain National Security Technologies and Products in Countries of Concern (Final Rule) implementing...more
An August 4 deadline is fast approaching for comments to the U.S. Department of the Treasury’s Notice of Proposed Rulemaking (NPRM) that was issued June 21. The NPRM will restrict, for national security purposes, specific...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
On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more
The Situation: On June 21, 2024, the U.S. Department of the Treasury ("Treasury") issued a notice of proposed rulemaking to implement President Biden's executive order mandating national security review of certain U.S....more
On February 2024, the U.S. Treasury released the 2024 National Money Laundering Risk Assessment (NMLRA) which examines the current money laundering environment and identifies the ways in which criminals and other actors seek...more
On August 9, 2023, President Biden issued an Executive Order entitled, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the “EO”), declaring a national...more
After over a year of anticipation, on August 9, 2023, President Biden issued an Executive Order (“EO”) outlining a new regulatory regime for outbound investments from the United States. The EO targets certain U.S. investments...more
President Biden issued a long-awaited executive order, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the Executive Order or E.O.), on August 9, 2023,...more
The US government’s multibranch effort to implement a new regulatory regime designed to regulate outbound investments based on national security concerns moved forward with the White House’s August 9, 2023 Executive Order, EO...more
The application cycle for the first round of credits will soon open. Treasury’s additional guidance clarifies what types of facilities may qualify for credits, the submission process and the selection criteria for evaluating...more
Legislative responses to recent banking industry failures could include reinstating various rules that formerly applied to banks with more than $100 billion in assets. There are a variety of measures which bank depositors...more
On Thanksgiving of 2014, I received an urgent call asking me to be in London in 24 hours. My assignment was to run the advanced forensics recovery team serving several foreign offices of Sony Pictures in the wake of a...more
The U.S. government continues to increase scrutiny over certain foreign investments in the United States and critical supply chain security. On 15 September 2022, President Biden signed the “Executive Order on Ensuring Robust...more
Editor’s Note: On July 27, 2022, HaystackID shared an educational webcast on the topic of Committee on Foreign Investment in the United States (CFIUS) compliance. CFIUS is a U.S. government interagency committee with the...more
Many investors, traditional and progressive, are looking hard at cryptocurrency investments as a way to diversify their portfolios. However, there are still multiple known “unknowns” about this new market, including the...more