On April 2, 2025, the Trump Administration announced new, comprehensive tariff rates representing the most significant change in US trade policy in a generation—a paradigm shift from an era of low tariffs to an approach based...more
4/10/2025
/ China ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Reciprocity Rules ,
Regulatory Agenda ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
On February 21, 2025, President Trump issued a memorandum “America First Investment Policy” (the Investment Memo or Memo), in which the President aims to modify the US Government’s approach to inbound and outbound foreign...more
In his first tangible action implementing his campaign promise to impose broad tariffs, on February 1, 2025, President Trump issued three Executive Orders (the EOs) directing that across-the-board tariffs be imposed on goods...more
2/11/2025
/ Canada ,
China ,
Energy Sector ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Legislative Agendas ,
Mexico ,
National Security ,
Regulatory Agenda ,
Tariffs ,
Trade Act of 1974 ,
Trump Administration
On February 5, 2025, the US Department of Justice (DOJ) issued two memoranda, General Policy Regarding Charging, Plea Negotiations, and Sentencing and Total Elimination of Cartels and Transnational Criminal Organizations,...more
2/10/2025
/ Anti-Bribery ,
Anti-Money Laundering ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Priorities ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Immigration Enforcement ,
Immigration Reform ,
National Security ,
Trump Administration
On January 15, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) published an interim final rule (IFR) that imposes new controls on advanced computing integrated circuits (Advanced ICs) and certain...more
1/20/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Export Controls ,
Final Rules ,
Foreign Policy ,
Interim Final Rules (IFR) ,
National Security ,
Regulatory Agenda ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department
On January 10, 2025, the Biden Administration issued a broad sanctions package targeting the Russian energy sector, 10 days in advance of the transition to the incoming Trump Administration. The new sanctions also added two...more
1/14/2025
/ Biden Administration ,
Blocked Person ,
Department of Energy (DOE) ,
Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
U.S. Treasury ,
UK
Proposed rule would create new prohibitions on transactions of sensitive personal data and government-related data -
The Department of Justice (DOJ) has proposed a new rule aimed at preventing access of China and other...more
Cybersecurity requirements continue to proliferate, both globally and within the US. Whether because of these new requirements, or because of the escalating threat environment, companies should urgently consider assessing...more
For the first time in 46 years, the Federal Trade Commission (FTC) has approved extensive updates to the Hart-Scott-Rodino (HSR) Act premerger notification form and associated instructions, as well as the premerger...more
On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more
7/9/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
China ,
Covered Person ,
Covered Transactions ,
Data Privacy ,
Data Security ,
Foreign Persons ,
Information Technology ,
Investment ,
National Security ,
Popular ,
Prohibited Transactions ,
Proposed Regulation ,
Regulatory Agenda ,
U.S. Treasury
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
The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran -
The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more
4/29/2024
/ China ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Iran ,
National Security ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
Statute of Limitations ,
Trade Policy ,
UK
Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more
2/27/2024
/ Biden Administration ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Federal Procurement Systems ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Payment Systems ,
Russia ,
Russian Military Procurement ,
SDN List ,
Ukraine ,
US State Departments
The Federal Trade Commission (FTC) announced on Monday, January 22, 2024 that the jurisdictional thresholds for filings under the Hart-Scott-Rodino Antitrust Improvements Act (HSR Act) will increase in 2024, including an...more
1/26/2024
/ Acquisitions ,
Antitrust Division ,
Department of Justice (DOJ) ,
Federal Trade Commission (FTC) ,
Filing Fees ,
Hart-Scott-Rodino Act ,
Mergers ,
Premerger Notifications ,
Size of Persons Test ,
Size of Transaction Test ,
Threshold Requirements
On October 30, 2023, the Biden Administration issued the groundbreaking Executive Order 14110 on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (Order), which sets in motion a comprehensive...more
11/13/2023
/ Artificial Intelligence ,
Biden Administration ,
Civil Rights Act ,
Climate Change ,
Competition ,
Cybersecurity ,
Department of Homeland Security (DHS) ,
Department of Labor (DOL) ,
Executive Orders ,
Federal Contractors ,
Government Agencies ,
Innovation ,
Innovative Technology ,
Intellectual Property Protection ,
NIST ,
Popular ,
Privacy Laws ,
Public Policy ,
Regulatory Agenda ,
Technology Sector
After months of deliberation, on August 9, 2023, President Biden issued the executive order “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (Order), with...more
On July 31, 2023, the US Department of the Treasury-led Committee on Foreign Investment in the United States (CFIUS or the Committee) released its annual report for calendar year 2022 (2022 Report), which provides insight...more
Last week the Department of Justice and Federal Trade Commission (Antitrust Agencies) jointly released a draft of their long-awaited revised Merger Guidelines, which reflect the Biden Administration’s ramped up merger...more
7/28/2023
/ Acquisitions ,
Antitrust Division ,
Antitrust Provisions ,
Biden Administration ,
Competition ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Federal Trade Commission (FTC) ,
Joint Policy Statements ,
Merger Reviews ,
Mergers ,
New Guidance ,
Online Platforms ,
Vertical Mergers
On June 27, 2023, the Federal Trade Commission (FTC) and the Antitrust Division of the US Department of Justice (DOJ, and together with the FTC, the Agencies) announced proposed changes to the premerger notification filing...more
7/7/2023
/ Acquisitions ,
Antitrust Division ,
Comment Period ,
Department of Justice (DOJ) ,
Federal Trade Commission (FTC) ,
Hart-Scott-Rodino Act ,
Merger Controls ,
Merger Reviews ,
Mergers ,
NPRM ,
Pre-Merger Filing Requirements ,
Premerger Notifications
On May 19, 2023, the Biden Administration along with leaders of the Group of Seven (G7), unveiled a new package of sanctions. The G7 leaders released a joint statement reaffirming their commitment to offer “the financial,...more
6/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Entity List ,
Evasion ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
SDN List ,
Third-Party ,
U.S. Commerce Department ,
Ukraine
On April 19, 2023, the US Department of Commerce Bureau of Industry and Security (BIS) entered into a settlement agreement wherein Seagate Technology LLC and Seagate Singapore International Headquarters Pte. Ltd....more
4/27/2023
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Huawei ,
Sanction Violations ,
Settlement Agreements ,
U.S. Commerce Department
The Federal Trade Commission (FTC) announced on Monday, January 23, 2023 that the jurisdictional thresholds for filings under the Hart-Scott-Rodino Antitrust Improvements Act (HSR Act) will increase in 2023, including an...more
Amid the 4,000 pages of provisions in the recently enacted Fiscal Year 2023 National Defense Authorization Act (NDAA) are prohibitions and associated requirements relating to the federal procurement of certain Chinese...more
1/3/2023
/ China ,
Covered Entities ,
Defense Sector ,
Department of Defense (DOD) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Information Technology ,
National Security ,
NDAA ,
Procurement Guidelines ,
Semiconductors ,
Telecommunications
Oil price cap -
The oil price cap has been co-ordinated by the G7 in order to make EU, UK and US services (including (re)insurance) available to third country importers and exporters as long as the price paid for...more
12/12/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
G7 ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
SDN List ,
Switzerland ,
Third Country Entities (TCEs) ,
UK ,
Ukraine
Recently, the US Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule imposing additional export controls on certain advanced computing and semiconductor manufacturing items and for...more
11/4/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Interim Final Rules (IFR) ,
Manufacturers ,
Military End Use ,
National Security ,
Technology Sector ,
U.S. Commerce Department