News & Analysis as of

U.S. Treasury National Security Penalties

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

Seward & Kissel LLP

Treasury Department Confirms: No Fines or Penalties in Connection with BOI Reporting Deadlines

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While the March 21, 2025 filing deadline under the Corporate Transparency Act (the “CTA”) remains in place, the Treasury Department announced on March 2nd that it will not enforce any penalties or fines associated with...more

Buchalter

The U.S. Finalizes Outbound Investment Restrictions on Technology Development

Buchalter on

Precedent-Setting Investment Restrictions – On January 2, 2025, the U.S. will start restricting foreign investments by U.S. persons in certain national security technologies. The Outbound Investment Rule and associated...more

Holland & Knight LLP

Treasury Department Issues Proposed Rule to Enhance CFIUS Procedures, Enforcement Authorities

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Almost six years after the enactment of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), the U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS),...more

Eversheds Sutherland (US) LLP

Treasury proposes expansion of CFIUS authorities

On April 11, 2024, the US Department of the Treasury issued, for notice and comment, proposed modifications (Proposed Rule) to certain Committee on Foreign Investment in the United States (CFIUS or Committee) regulations. In...more

Bass, Berry & Sims PLC

CFIUS Update: Larger Penalties, Sharper Monitoring

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On April 11, the U.S. Treasury Department promulgated a Notice of Proposed Rulemaking (NPRM) amending the regulations that govern the operations of the Committee on Foreign Investment in the United States (CFIUS) to increase...more

Torres Trade Law, PLLC

Less Bark and More Bite? CFIUS Proposed Rule Enhancing Enforcement Capabilities

Torres Trade Law, PLLC on

A new proposed rule issued by the Committee on Foreign Investment in the United States (CFIUS) seeks to expand the scope of information that CFIUS can request from parties, expand its ability to monitor and investigate...more

Akin Gump Strauss Hauer & Feld LLP

CFIUS Proposes Expanded Enforcement Authorities and Increased Penalties

Key Points - On April 15, 2024, the Treasury Department published a proposed rule that would amend the Committee on Foreign Investment in the United States (CFIUS) regulations to expand CFIUS’s enforcement authorities....more

Latham & Watkins LLP

Treasury Proposes New CFIUS Regulations to Expand Monitoring and Enforcement Authorities: 5 Key Takeaways

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The proposal signals a continued effort to expand CFIUS’s enforcement scope and update penalties. On April 11, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed Rulemaking (the Proposed Rule)...more

Wiley Rein LLP

Treasury Proposes Stronger CFIUS Penalties, Broader Subpoena and Enforcement Powers

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The U.S. Department of the Treasury (Treasury), which chairs the Committee on Foreign Investment in the United States (CFIUS or the Committee), recently published a Notice of Proposed Rulemaking (NPRM) that would amend the...more

Proskauer - Regulatory & Compliance

CTA – Accessing Beneficial Ownership Information

On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final rule on Beneficial Ownership Information Access and Safeguards (the “Access Rule”) laying out the...more

Goodwin

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

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On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

Husch Blackwell LLP

Corporate Transparency Act Guide

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On January 1, 2024, the Corporate Transparency Act (CTA) will go into effect, and if your business is deemed to be a Reporting Company under the CTA, the clock will begin ticking on new federal reporting obligations....more

Torres Trade Law, PLLC

Five Key Takeaways from the 2023 CFIUS Conference

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On September 14, 2023, the U.S. Department of the Treasury held the annual Committee on Foreign Investment in the United States (“CFIUS”) Conference in Washington, DC. The interagency Committee is tasked with reviewing...more

Seward & Kissel LLP

United States Issues New Executive Order that Begins Rulemaking Process to Impose Regulations on Certain Outbound Investments in...

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On August 9, 2023, President Biden issued Executive Order 14105 “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern.” The Executive Order targets certain U.S....more

King & Spalding

Executive Order Establishes New Outbound Investment Screening Program

King & Spalding on

Prohibitions targeted to prevent China’s exploitation of dual-use technology - On August 9, 2023, President Biden signed a historic Executive Order on Addressing United States Investments in Certain National Security...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

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On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

Lowenstein Sandler LLP

Feds Reach Into Real Estate Deals Extended In Name Of National Security

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Could your upcoming commercial real estate transaction or investment raise national security concerns? Under recently developed federal law, the Committee on Foreign Investment in the United States (CFIUS), a...more

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