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New Tariffs and Metal “Melt-and-Pour” Requirements Implemented to Prevent Chinese Circumvention Through Mexico

On July 10, 2024, the U.S. Government narrowed the tariff exclusions on imports of certain steel and aluminum articles from Mexico, citing national security concerns. These measures effectively impose new tariffs aimed at...more

United States Government Doubles Statute of Limitations for Sanctions Violations

Shrouded within the supplemental emergency appropriations bill for Israel, Ukraine, and Taiwan, the 21st Century Peace through Strength Act passed by Congress and signed into law significantly increases the statute of...more

United States Attorney’s Offices Announce Innovative Voluntary Self-Disclosure Programs for Individuals

Last year, on February 22, 2023, the Department of Justice (DOJ) announced a corporate Voluntary Self-Disclosure (VSD) policy, which is applicable to all U.S. Attorney’s Offices, setting nationwide incentives for voluntary...more

Frederick Douglass Foundation, Inc., et al. v. District of Columbia: Recent Case Illustrates Importance of Governmental Compliance...

Equality under the law is a cardinal principle of the United States’ constitutional order. This principle extends to laws regulating speech. Specifically, the government does not get to single out a particular viewpoint and...more

Scope of FCA Liability Illustrated In Recent Actions Against Higher Education Institutions

In the past five years, the Federal Government and “Qui Tam” Realtors have ramped up False Claims Act (“FCA”) actions against higher education institutions. These actions highlight the scope and breadth of potential FCA...more

CFIUS & Export Controls: The Foreign Investment Regulations Putting Buyers, Sellers, and M&A Practitioners at Risk

In recent memory, enforcement of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) regulations has been mostly limited and sporadic. But recently, the U.S. government is reviving and...more

Congress Takes Aim at Organizational Conflicts of Interest for Government Contractors and Consultants

A major issue faced by government contractors (at any tier) is the risk of organizational conflicts of interest (“OCIs”). To reform the OCI regulatory framework, Congress recently passed the Preventing Organizational...more

CFIUS Releases Guidance Concerning Enforcement and Penalty Actions

On October 20, 2022, the Committee on Foreign Investment in the United States (“CFIUS”) issued the “CFIUS Enforcement and Penalty Guidelines” (the “Guidelines”). These are the first-ever Guidelines issued by CFIUS which is a...more

Enhanced Export Regulatory Enforcement

In a continued theme of increased enforcement of export controls, the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce released a memorandum that announced a stricter Administrative Enforcement...more

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