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Understanding the Cybersecurity Maturity Model Certification (CMMC) Program: Essential Steps for Defense Contractors

The Department of Defense (DoD) published the updated Cybersecurity Maturity Model Certification (CMMC) Program to enforce existing cybersecurity standards across the defense industrial base. This program is designed to...more

The Cybersecurity Maturity Model Certification Program – Defense Contractors Must Rapidly Prepare and Implement

The Department of Defense (DoD) has officially launched the Cybersecurity Maturity Model Certification (CMMC) Program, which requires federal contractors and subcontractors across the Defense Industrial Base (DIB) to comply...more

US Treasury Department Moves Closer to Implementing Outbound Investment Restrictions Through Latest Proposed Regulations

On 21 June 2024, the Office of Investment Security of the US Department of the Treasury (Treasury) issued proposed regulations to implement President Biden’s August 2023 Executive Order on Addressing United States Investments...more

State Department Aims to Streamline Export Controls for Future Collaboration Among the United States, United Kingdom, and...

On 1 May 2024, the US State Department’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule to amend the International Traffic in Arms Regulations (ITAR) to support the goals of the trilateral security...more

The Committee on Foreign Investment in the United States Sharpens Its Enforcement Edge: Proposed Regulatory Revisions Expand...

On 15 April 2024, the Treasury Department’s Office of Investment Security published a Proposed Rule to revise the regulations governing the Committee on Foreign Investment in the United States (CFIUS or the Committee). The...more

President Biden Issues Executive Order Restricting Bulk Transfers of Sensitive Personal and US Government-Related Data

On 28 February 2024, President Biden issued Executive Order 14117 of February 28, 2024, Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern (EO) aimed...more

Biden Administration Takes Actions to Bolster Maritime Cybersecurity in the US Maritime Domain

The maritime industry is undergoing a significant transformation that involves increased use of cyber-connected systems, coinciding with increased nation-state and cybercriminal targeting of cyber systems in ports and...more

DOJ, FBI, and SEC Provide Guidance For Delay Requests Relating to Disclosure of Cybersecurity Incidents Under Form 8-K

On 18 December 2023, the new rules of the US Securities and Exchange Commission (SEC) regarding disclosure of material cybersecurity incidents under Item 1.05 of Form 8-K went into effect, requiring companies to report a...more

US Government Highlights Sanctions and Export Control Obligations to Improve Compliance and Prevent Evasion

Driven by concerns around increasing sanctions evasion activities by Russia, China, Iran and North Korea, the US Government is stepping up enforcement and warning companies in the extended cargo and shipping supply chain to...more

President Biden Issues Wide-Ranging Executive Order on Artificial Intelligence

On 30 October 2023, President Biden issued a long-awaited executive order (EO) on artificial intelligence (AI). The EO itself is available here, and a one-page fact sheet issued by the White House is available here. The...more

US Government Revises Comprehensive Export Controls on Semiconductors and Semiconductor Manufacturing Equipment

On 17 October 2023, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued two new Interim Final Rules (collectively, the Updated Rule) that significantly revise and expand controls under the US Export...more

OFAC Imposes First Sanctions for Russian Oil Price Cap Violations

For the first time, on 12 October 2023, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on vessels and their owners for breaching the price cap on seaborne Russian crude oil...more

United States Eases Sanctions on Venezuela

The United States eased certain economic sanctions against Venezuela on 18 October 2023 in response to the signing of an electoral roadmap agreement between the Maduro regime and Venezuela’s Unitary Platform. Under this...more

Complying with FinCEN's Beneficial Ownership Reporting Rules Under the Corporate Transparency Act

Starting on 1 January 2024, entities will need to comply with the reporting rules under the Corporate Transparency Act (CTA).1 The implementing Treasury regulations were published on 30 September 2022.2 The CTA applies both...more

United States Imposes Unprecedented Outbound Investment Controls Focused on China

On 9 August 2023, President Biden issued a long anticipated executive order imposing certain limitations, reporting requirements, and prohibitions on outbound investment from the United States into certain sensitive industry...more

CFIUS Proposal Underscores Risks in Foreign Real Estate Acquisitions in the United States

The Committee on Foreign Investment in the United States (CFIUS or the Committee) recently proposed expanding the scope of its jurisdiction to review real estate transactions to add over 200,000 square miles of land...more

Russia-Related Export Controls Continue to Escalate

In a set of actions in coordination with G7 allies, US and UK export control authorities recently announced significant escalations of sanctions and export controls against Russia and Belarus. These actions indicate continued...more

Secure Software Regulations and Self-Attestation Required for Federal Contractors

Government contractors providing software across the federal government’s supply chain will be required later this year to comply with a new Secure Software Design Framework (SSDF). The SSDF requires software vendors to...more

US Government to Penalize Failures to Disclose Possible Export Control Violations and Incentivize Reporting of Others' Violations

A common approach in dealing with potential violations of the US export control laws is to undertake a voluntary disclosure to the regulators and thereby benefit from long-standing policies that favor such disclosure by...more

U.S. Government Imposes Significant New Export Controls on Semiconductor, Semiconductor Manufacturing Equipment, and...

On 7 October 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued two Interim Final Rules (collectively, The Rule) that significantly enhance U.S. export controls as applied to advanced...more

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