News & Analysis as of

National Security Compliance U.S. Treasury

Baker Botts L.L.P.

Navigating the CFIUS Fast Track Program

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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

Fenwick & West LLP

United States Lifts Comprehensive Sanctions on Syria, Export Controls Remain For Now

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On June 30, 2025, the White House issued Executive Order 14312, Providing for the Revocation of Syria Sanctions (the Syria EO), terminating U.S. comprehensive sanctions on Syria effective July 1, 2025. ...more

Thomas Fox - Compliance Evangelist

Compliance Tip of the Day: Standing at the Turning Point

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

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

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

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On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Foley Hoag LLP

Corporate Transparency Act Revived After Last Remaining Nationwide Preliminary Injunction is Lifted - Reporting Deadlines Extended

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On February 18, 2025, the U.S. Federal District Court for the Eastern District of Texas lifted the last remaining nationwide preliminary injunction of the CTA in the Smith case. This follows a decision on January 23, 2025, by...more

Amundsen Davis LLC

The Corporate Transparency Act Is Back in Effect With a March 21 Reporting Deadline

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in a February 19, 2025 alert that the Corporate Transparency Act (CTA) is back in effect. The new deadline for most companies to...more

Nelson Mullins Riley & Scarborough LLP

Corporate Transparency Act Reporting Obligations Reinstated; Deadline Extended 30 Days

On February 19, 2025, FinCEN released a statement that BOI reporting obligations under the CTA are back in effect, after a recent U.S. District Court decision in the ongoing case of Smith et al. v. U.S. Department of the...more

McGlinchey Stafford

CTA’s Beneficial Ownership Reporting Requirement Resumes – At Least for Now

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As the saga of on-again-off-again requirements continues to unfold, FinCEN’s Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have undergone significant changes due to...more

Akin Gump Strauss Hauer & Feld LLP

2025 Perspectives in Private Equity: Cross-border Investment Review and New Restrictions

Navigating the complex landscape of foreign investment review is crucial for private equity (PE) firms operating in an international landscape. The Committee on Foreign Investment in the United States (CFIUS) continues to be...more

Seward & Kissel LLP

OFAC Announces Two New Waves of Sanctions Targeting Russia’s Oil Production and Exports, Military-Industrial Base, and Sanctions...

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On January 10 and January 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sweeping sanctions targeting Russia’s oil production and exports, military-industrial base, and other...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

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The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

Baker Botts L.L.P.

Compliance, Enforcement, and Litigation Risk Considerations from President Trump’s Executive Order on Designating New Foreign...

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On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The order directs the...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

Seward & Kissel LLP

New Restrictions on Investments into Chinese Entities: Considerations for Advisers, Private Funds, and Investors

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U.S. law has long subjected foreign investments into the U.S. to review and restriction by the Committee on Foreign Investment in the United States (“CFIUS”), but outside of economic sanctions programs, has typically not...more

Sheppard Mullin Richter & Hampton LLP

Looking Beyond FedRAMP – Lessons from the U.S. Treasury Cybersecurity Incident

In the ever-evolving world of cybersecurity, even organizations that meet stringent security standards can be victims of sophisticated cyberattacks. A notable example of this is the December 8, 2024 cybersecurity incident...more

Akin Gump Strauss Hauer & Feld LLP

Designation Of Ansar Allah as a Foreign Terrorist Organization (Trump EO Tracker)

Summary This Order re-designates Ansar Allah (also known as the Houthis) a Foreign Terrorist Organization (“FTO”), to be effective within 45 days. The first Trump Administration had previously designated the Houthis as an FTO...more

K&L Gates LLP

New US Sanctions Target Russia’s Energy Sector

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On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of new sanctions targeting Russia’s energy sector. In an effort to curtail Russia’s oil revenue and ability...more

Alston & Bird

OFAC Announces Sanctions Against Chinese-Based Cybersecurity Company

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On January 3, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a Chinese-based cybersecurity company, Integrity Technology Group, Inc. (“Integrity Tech”). These sanctions...more

Holland & Knight LLP

Outbound Investment Screening Rule Goes into Effect

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The U.S. Department of the Treasury's Final Rule on outbound investment screening went into effect on Jan. 2, 2025. The Final Rule establishes a much-awaited outbound investment screening regime, implementing Executive Order...more

Fox Rothschild LLP

Investments in Chinese Technology Companies Limited by New US Outbound Investment Rule

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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

Troutman Pepper Locke

OFAC's Latest General Licenses and FAQs Related to Russian Sanctions

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On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...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

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