On April 11, 2025, the Department of Justice (DOJ) announced additional guidance regarding the implementation of the Final Rule (the “Rule”), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and...more
On Wednesday, February 5, 2025, the newly confirmed Attorney General (AG) Pam Bondi issued fourteen memoranda to all Department of Justice (DOJ or the “Department”) employees regarding a wide range of new policies and...more
2/19/2025
/ Anti-Corruption ,
Bribery ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
National Security ,
White Collar Crimes
On January 16, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) addressing national security concerns regarding information and communications technology...more
1/22/2025
/ Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Final Rules ,
Hardware ,
Imports ,
National Security ,
Russia ,
Software ,
Supply Chain ,
U.S. Commerce Department
On January 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) titled “Framework for Artificial Intelligence Diffusion.” The IFR builds on a long series of...more
INTRODUCTION...
On January 16, 2025, President Biden issued an Executive Order (EO) on Strengthening and Promoting Innovation in the Nation’s Cybersecurity, to further address increasing threats from nation-state actors...more
On December 27, 2024, the Department of Justice (DOJ) released a Final Rule, Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons....more
1/7/2025
/ Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Brokers ,
Data Management ,
Department of Justice (DOJ) ,
Due Diligence ,
Exports ,
Final Rules ,
National Security ,
Personal Data ,
Sensitive Personal Information
As global economic and geopolitical environments enter a new era, companies need to continuously develop and adjust their coherent global business strategies to secure and further expand business opportunities in all markets...more
1/2/2025
/ Acquisitions ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Business Opportunities ,
Business Strategies ,
CFIUS ,
China ,
Compliance ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Entity List ,
Exports ,
Final Rules ,
Financial Transactions ,
Forced Labor ,
Foreign Investment ,
Importers ,
Imports ,
Investment ,
Joint Venture ,
National Security ,
NPRM ,
Prohibited Transactions ,
Real Estate Transactions ,
Regulatory Requirements ,
Semiconductors ,
Sensitive Personal Information ,
Supply Chain ,
Trade Relations ,
Uyghur Forced Labor Prevention Act (UFLPA)
On December 20, 2024, the US Department of Justice (DOJ) issued a long-awaited notice of proposed rulemaking (NPRM) to revise regulations under FARA, three years after an Advance Notice of Proposed Rulemaking sought input on...more
1/2/2025
/ Department of Justice (DOJ) ,
Foreign Agents ,
Foreign Agents Registration Act (FARA) ,
Foreign Corporations ,
Foreign Governments ,
Foreign Nationals ,
National Security ,
NPRM ,
Proposed Regulation ,
Registration Requirement ,
Reporting Requirements
After yet another banner year for the Foreign Agents Registration Act (FARA)—including high-profile prosecutions, an all-time high in registrations, a record number of inspections, and a key DC Circuit decision—US Department...more
On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more
On October 28, 2024, the US Department of the Treasury (“Treasury”) issued a Final Rule to require the notification or prohibition of certain outbound investments and other transactions by US persons involving persons of...more
On October 24, 2024, President Biden issued the first-ever National Security Memorandum (NSM) on artificial intelligence (AI), fulfilling another directive (subsection 4.8) set forth in the Administration’s Executive Order on...more
On October 21, 2024, the Department of Justice (DOJ) released an unpublished Notice of Proposed Rulemaking (NPRM), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by...more
10/24/2024
/ Data-Sharing ,
Department of Justice (DOJ) ,
International Data Transfers ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
NPRM ,
Personal Data ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Reform ,
Sensitive Personal Information
By now, companies across all industries have become familiar with the lifecycle and stages of a ransomware incident. Generally, once an attack is contained, remediation and rebuilding will follow. Shortly after, the crisis...more
10/14/2024
/ Attorney-Client Privilege ,
Class Action ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Security ,
Incident Response Plans ,
Invasion of Privacy ,
Litigation Strategies ,
Personally Identifiable Information ,
Ransomware ,
Risk Mitigation
On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute, announced three key updates to...more
On September 9, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (BIS) released notice of a proposed rule to create a mandatory reporting requirement for artificial intelligence (AI)...more
On September 6, 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) issuing new export controls on quantum computing, semiconductor, and other advanced technology,...more
As predicted earlier this year in our January update, the US Department of Justice (DOJ) has continued to ramp up enforcement of the Foreign Agents Registration Act (FARA) and related political laws through criminal...more
On August 15, 2024, the Department of Defense (DoD) published a proposed rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate contractual requirements related to the Cybersecurity...more
On August 14, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) announced a $60 million penalty, “the largest penalty CFIUS has ever issued,” following its finding of material violations...more
On August 1, 2024, the US Department of Justice (“DOJ” or “Department”) released highly anticipated details of its new Corporate Whistleblower Awards Pilot Program (“Pilot Program”), with Principal Deputy Assistant Attorney...more
8/6/2024
/ CFTC ,
Corporate Crimes ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Financial Crimes ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
The US government could soon allow private US military contractors to operate in Ukraine to maintain and service weapons supplied by the United States (the “MC Policy”), according to a recent CNN news report. This type of...more
On June 20, 2024, the Department of Commerce's Bureau of Industry and Security (BIS) issued a Final Determination (“Determination”) prohibiting Kaspersky Lab, Inc.—the US subsidiary of the Russia-based antivirus software and...more
On May 2, 2024, the Department of Defense (DoD) issued a class deviation to DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting.
The deviation relates to contractors’ compliance with...more
On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the “Act”). While much of the focus centered on the foreign aid package for Israel, Ukraine, and the Indo-Pacific, the bill...more
4/30/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Cybersecurity ,
Economic Sanctions ,
Export Controls ,
Foreign Aid ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
National Security Supplemental ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Reform ,
Statute of Limitations ,
TWEA