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Prohibited Transactions International Emergency Economic Powers Act (IEEPA)

Parker Poe Adams & Bernstein LLP

Key Compliance Measures Start This Fall for Companies Under New DOJ Data Security Program

Earlier this spring, the U.S. Department of Justice’s National Security Division (NSD) launched the data security program (DSP). The program is designed to address national security risks posed by foreign adversaries' access...more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

Hinch Newman LLP on

On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

Wiley Rein LLP

DOJ and CISA Propose New National Security Program to Regulate Foreign Access to Sensitive Data

Wiley Rein LLP on

On October 21, 2024, the U.S. Department of Justice (Department or DOJ) and the U.S. Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) issued proposals – required by the...more

Latham & Watkins LLP

US Treasury Department Issues Notice of Proposed Rulemaking on Implementation of Outbound Investment: 5 Key Takeaways

Latham & Watkins LLP on

The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...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

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - May 2024

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

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - May 2024

BakerHostetler on

In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Biden Administration Announces New Measures to Safeguard Americans’ Sensitive Personal Data

On February 28, 2024, the Biden administration announced new cybersecurity-related measures, including an executive order (EO) and advance notice of proposed rulemaking (ANPRM), intended to address the bulk flow of Americans’...more

Latham & Watkins LLP

White House Issues Outbound Investment Executive Order and Treasury Department Solicits Comments on This New Regulatory Program: 5...

Latham & Watkins LLP on

After publicly signaling support for an outbound investment screening mechanism in July 2022, the Biden Administration has issued a long-anticipated Executive Order to address certain investments by US persons in “countries...more

Hogan Lovells

Legislation to grant U.S. government sweeping authority over ICT-related national security threats

Hogan Lovells on

On 7 March 2023, U.S. Senators Mark Warner and John Thune introduced the Restricting the Emergence of Security Threats that Risk Information and Communications Technology (RESTRICT) Act, sweeping legislation aimed at...more

Akin Gump Strauss Hauer & Feld LLP

Biden Administration Reviewing Comments on Interim Final ICTS Rule

Key Points - On January 19, 2021, the U.S. Commerce Department published an interim final rule (IFR) to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Department of Energy Prohibits Transactions in Certain Bulk-Power System Electric Equipment Serving Critical Defense...

On December 17, 2020, the U.S. Department of Energy (DOE or the “Department”), pursuant to President Trump’s May 2020 Executive Order 13920 on “Securing the United States Bulk-Power System” (EO), which we addressed here,...more

Morgan Lewis

Implications of the New Executive Order Prohibiting Transactions in Publicly Traded Securities of Chinese Military Companies

Morgan Lewis on

The new Executive Order (EO or the Order) bans transactions by US persons in publicly traded securities of companies identified as “Chinese military companies,” and includes a ban on trading in derivatives of those securities...more

White & Case LLP

President Trump Issues Executive Order on Securing the United States Bulk-Power System

White & Case LLP on

On May 1, 2020, President Trump issued an Executive Order prohibiting the acquisition, importation, transfer, or installation of certain “bulk-power system electric equipment” where the transaction involves property in which...more

Bass, Berry & Sims PLC

U.S. District Court Deals Rare Defeat to OFAC in U.S. Sanctions Matter

Bass, Berry & Sims PLC on

• $2 million penalty against Exxon overturned • Court concluded that OFAC failed to provide clear notice of violative conduct • Companies are at risk when acting in context of ambiguous agency guidance At the end of...more

ArentFox Schiff

US Administration Tests the Water on New Unheard-of Government Review of International Technology Transactions

ArentFox Schiff on

Under this new evaluation process, Commerce can prohibit companies from engaging in a wide variety of transactions and order them to cease using the information technology or telecommunication system in question even if it is...more

Sheppard Mullin Richter & Hampton LLP

New Executive Order To Further Restrict Business with Huawei and Other Foreign Adversaries Engaged in Cyber Espionage

On May 15, 2019, President Trump issued an Executive Order (“EO”) targeting activities of certain foreign telecommunications companies based in hostile countries. Entitled “Securing the Information and Communications...more

Faegre Drinker Biddle & Reath LLP

President Trump Prohibits Most Trade and Transactions with Huawei of China and Sets the Stage for Similar Actions against other...

On May 15, 2019, President Trump issued an Executive Order (EO), “Securing the Information and Communications Technology and Services Supply Chain.” The EO directs the U.S. Department of Commerce to lead an interagency effort...more

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