China has recently taken several actions showing its commitment to counter trade restrictions imposed by other countries. In March 2025, it released regulations implementing the 2021 Anti-Foreign Sanctions Law. In tandem with...more
4/14/2025
/ China ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Foreign Policy ,
Foreign Relations ,
International Trade ,
Multinationals ,
National Security ,
Regulatory Requirements ,
Trade Relations
The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more
3/3/2025
/ Anti-Money Laundering ,
Cartels ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Services Industry ,
Justice Against Sponsors of Terrorism Act (JASTA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury
On January 15, 2025, the European Commission ("EC") published a Recommendation ("EU Recommendation") urging European Union Member States to start reviewing outbound investments outside of the EU in three strategic sectors:...more
The U.S. Commerce Department's Bureau of Industry and Security ("BIS") issued a rule establishing a framework to prevent U.S. adversaries from accessing the most advanced artificial intelligence ("AI") systems while...more
2/6/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Cybersecurity ,
Export Controls ,
Innovative Technology ,
Licensing Rules ,
National Security ,
Regulatory Requirements ,
Risk Management ,
Semiconductors ,
U.S. Commerce Department
The final rule establishes prohibitions and restrictions on the transfer of certain data due to national security risks from specified countries of concern....more
1/16/2025
/ Data Brokers ,
Data Privacy ,
Data Protection ,
Data Transfers ,
Department of Justice (DOJ) ,
Export Controls ,
Final Rules ,
International Data Transfers ,
National Security ,
Personal Data ,
Regulatory Requirements ,
Reporting Requirements
The United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control ("OFAC") exceeded the authority granted by the International Emergency Economic Powers Act ("IEEPA") when it added the...more
The Transportation Security Administration's ("TSA") proposed rule would require owners and operators of certain pipeline, freight railroad, passenger railroad, rail transit, and over-the-road bus ("OTRB") systems to...more
12/2/2024
/ Comment Period ,
Cybersecurity ,
Infrastructure ,
Oil & Gas ,
Pipelines ,
Proposed Rules ,
Railroads ,
Regulatory Agenda ,
Risk Management ,
Rulemaking Process ,
Surface Transportation ,
Transportation Security Administration
While the total number of filings declined in comparison to recent years, CFIUS's latest Annual Report to Congress highlights an uptick in penalties and an increased use of enforcement tools relating to national...more
On July 8, 2024, the U.S. Department of the Treasury ("Treasury") issued a proposed rule to expand the Committee on Foreign Investment in the United States' ("CFIUS") jurisdiction over certain categories of foreign investment...more
The Situation: On June 21, 2024, the U.S. Department of the Treasury ("Treasury") issued a notice of proposed rulemaking to implement President Biden's executive order mandating national security review of certain U.S....more
On May 13, 2024, President Biden signed into law the Prohibiting Russian Uranium Imports Act ("the Act"), which bans imports of low-enriched uranium ("LEU") produced in Russia or by a Russian entity. The Act will go into...more
On April 11, 2024, the Treasury Department announced a prepublication copy of a proposed rule amending the regulations of the Committee on Foreign Investment in the United States ("CFIUS") (the "Proposed Rule")....more
CISA's proposed rules will require organizations operating in U.S. critical infrastructure sectors to report cyber incidents within 72 hours and ransom payments within 24 hours. ...more
In recent years, the world has witnessed heightened sensitivity surrounding foreign investments, leading to increased regulatory scrutiny of foreign direct investments ("FDI") on the basis of national security concerns. The...more
Amending prior requirements, medical device manufacturers and importers have two years to comply with FDA's Quality Management System Regulation final rule, a similar approach to prior good manufacturing practices but with...more
The National Institute of Standards and Technology ("NIST") released a significant update to its framework, expanding its scope and reach to cover a broader audience and evolving cybersecurity risks and management issues....more
The U.S. Government has identified the exploitation of Americans' bulk sensitive personal data and U.S. government-related data by "countries of concern" as posing a national security risk....more
On December 26, 2023, the Department of Defense ("DoD") published a proposed rule to implement the Cybersecurity Maturity Model Certification ("CMMC") 2.0, which will establish comprehensive cybersecurity requirements for...more
The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") recently released two rules to update export controls on advanced semiconductors, semiconductor development and production, and items that support...more
On October 30, 2023, President Biden signed a first-of-its-kind executive order entitled, "Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence" ("AI")....more
11/1/2023
/ Algorithms ,
Artificial Intelligence ,
Biden Administration ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Department of Health and Human Services (HHS) ,
Executive Orders ,
Machine Learning ,
Regulatory Reform ,
Security Standards
The United States Patent and Trademark Office, along with the U.S. Departments of State and Commerce, sought initial public comment last week on draft guidelines entitled "International Guiding Principles for Organizations...more
10/31/2023
/ Algorithms ,
Artificial Intelligence ,
Comment Period ,
Copyright ,
Copyright Litigation ,
Cybersecurity ,
Intellectual Property Protection ,
Machine Learning ,
Technology ,
U.S. Commerce Department ,
USPTO
In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more
8/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Agents Registration Act (FARA) ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
The Biden administration has issued a long-anticipated executive order targeting U.S. outbound investment in certain Chinese industries; however, significant steps remain before these measures are fully implemented....more
8/22/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Comment Period ,
Executive Orders ,
Final Rules ,
Foreign Investment ,
National Security ,
Outbound Transactions ,
Popular ,
U.S. Treasury
On June 16, the U.S. Department of Commerce published a final rule, effective July 17, 2023, on Securing the Information and Communications Technology and Services ("ICTS") Supply Chain, signaling potential new actions on...more
In 2022, anti-money laundering ("AML") and sanctions controls were at the center of regulatory and enforcement activities in the United States and abroad. Globally, governments have continued to recognize the impact of AML...more