News & Analysis as of

Trump Administration Foreign Adversaries U.S. Commerce Department

Troutman Pepper Locke

The Least Known Risk in the Energy Sector: The “ICTS” National Security Rules

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There are unprecedented risks and opportunities emerging for companies in the energy sector as the Trump administration’s priorities start to come into focus. Many of those are well-known to the industry. Here’s one that’s...more

Morrison & Foerster LLP

Information and Communications Technology and Services Supply Chain Developments

On November 26, 2021, the U.S. Department of Commerce (“Commerce”) published a Proposed Rule that expanded on a prior rule implementing provisions of Executive Order 13873 on Securing the Information and Communications...more

Holland & Knight LLP

Biden Signs Executive Order to Protect Personal Data from Foreign Adversaries

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The U.S. government's efforts to secure sensitive personal data against foreign adversaries, primarily with an eye toward China, continue. On June 9, 2021, President Joe Biden signed the Executive Order on Protecting...more

Husch Blackwell LLP

Commerce Subpoenas Chinese Companies As ICTS Rules Take Effect

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Secretary of Commerce Gina M. Raimondo recently announced that the Department of Commerce (“Commerce”) had served subpoenas on multiple Chinese companies that provide information and communications technology and services...more

ArentFox Schiff

Commerce Department Signals Tough Approach on China Under Controversial Trump Tech Supply Chain EO

ArentFox Schiff on

The subpoena issuance suggests that the Biden Administration will continue the US Government’s assertive approach to China. The US Department of Commerce, on March 17, 2021, issued subpoenas on multiple Chinese companies...more

Wiley Rein LLP

A Final Trump EO Would Regulate Cloud, Software and Remote Computing Services

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On January 19, 2021, President Trump issued an Executive Order on Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities (EO), designed to regulate United...more

Husch Blackwell LLP

Commerce Department Publishes Interim Final ICTS "Foreign Adversary" Rules

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Key Point: New rules will impact the use of equipment and digital services sourced from China and other “foreign adversaries” in a wide variety of transactions and activities that potentially pose a risk to U.S. national...more

Wiley Rein LLP

Commerce Releases Rule for Reviewing Technology Transactions, Identifies Six Countries as “Foreign Adversaries”

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On January 14, 2021, the U.S. Department of Commerce (Department) released an interim final rule to implement President Trump’s 2019 Executive Order (EO) on “Securing the Information and Communications Technology and Services...more

Skadden, Arps, Slate, Meagher & Flom LLP

Commerce Department Takes Steps To Thwart Use of Information and Communications Technology and Services Associated With Foreign...

On November 27, 2019, the U.S. Department of Commerce (Commerce) published a proposed rule that would establish a new and especially broad power for the U.S. government to review and potentially block or unwind transactions...more

Akin Gump Strauss Hauer & Feld LLP

Commerce Issues Proposed Rule Implementing “Supply Chain Executive Order”

Key Points - On November 26, 2019, the U.S. Department of Commerce (“Commerce”) issued a proposed rule to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more

White & Case LLP

Department of Commerce Invites Comments on Proposed Rule Targeting Information and Communications Technology Transactions

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On November 27, 2019, the US Department of Commerce (Commerce) issued a notice of proposed rulemaking on the implementation of Executive Order 13873 (the EO), "Securing the Information and Communications Technology and...more

ArentFox Schiff

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

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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

Pillsbury - Global Trade & Sanctions Law

Commerce Department Issues New Proposed Rules on Telecommunications Supply Chain

On November 27, 2019, the US Commerce Department published a proposed rule implementing regulations following President Trump’s May 15, 2019 Executive Order 13783 (E.O.) on Securing the Information and Communications...more

Hogan Lovells

U.S. Commerce Department issues proposed rule to implement executive order on telecom supply chain

Hogan Lovells on

On 26 November 2019 the U.S. Department of Commerce issued a long-awaited proposed rule (or draft regulations) to implement Executive Order 13873, "Securing the Information and Communications Technology and Services Supply...more

Holland & Knight LLP

The Drama Around Huawei: Can U.S. Companies Do Business with the Chinese Chipmaker? - Huawei Seems to Be a Bargaining Chip in...

Holland & Knight LLP on

• President Donald Trump saying at the recent G20 Summit in Japan that American companies could keep selling products to Huawei Technologies Co. Ltd. (Huawei) was another installment in the drama surrounding the Chinese tech...more

White & Case LLP

US Targets Telecommunications Transactions Involving the Information and Communications Technology and Services Supply Chain

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On May 15, 2019, President Trump issued an executive order (EO), "Executive Order on Securing the Information and Communications Technology and Services Supply Chain," prohibiting certain transactions involving...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

Miller Canfield

New Executive Order Will Impact Ability of U.S. Companies to Use Certain Technologies Deemed a Security Risk

Miller Canfield on

President Donald J. Trump signed and issued an Executive Order (EO) on May 15, 2019, declaring a national emergency with respect to threats against U.S. information and communications technology or services (I&C Technologies)...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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