Josh Gelula at Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

2/7/2025 / Compliance , Economic Sanctions , Executive Orders , Foreign Policy , International Emergency Economic Powers Act (IEEPA) , National Security , Office of Foreign Assets Control (OFAC) , Popular , SDN List , U.S. Treasury

U.S. Department of Commerce expands controls on advanced semiconductors and establishes new controls on closed AI model weights

The new interim final rule imposes new global licensing requirements for ECCNs 3A090.a, 4A090.a, and corresponding .z items; controls for closed AI model weights; updated data center validated end-user authorizations;...more

2/6/2025 / Artificial Intelligence , Bureau of Industry and Security (BIS) , ECCNs , Export Administration Regulations (EAR) , Export Controls , International Trade , National Security , Regulatory Requirements , Semiconductors , Technology Sector

New DOJ rule limits cross-border data transfers to protect national security

The Department of Justice (DOJ) has issued a final rule limiting data transfers to China, Russia, and other designated “countries of concern.” The rule establishes a new national security program that bans specific types of...more

1/13/2025 / China , Cross-Border Transactions , Data Privacy , Data Protection , Department of Justice (DOJ) , Export Controls , Final Rules , National Security , Russia

Foreign direct investment (FDI) global legal guide

In line with international and European developments, Ireland has introduced a new regime to provide for a process to allow for certain transactions that may present risks to the security or public order of the State to be...more

1/10/2025 / Compliance , EU , Foreign Direct Investment , Foreign Investment , Government Agencies , Investment , National Security , Regulatory Oversight , Regulatory Requirements , Risk Management

Final rule expands CFIUS’s reach over real estate transactions

On November 1, 2024, the U.S. Department of the Treasury (“Treasury”), in its role as chair of the Committee on Foreign Investment in the United States (“CFIUS”), issued a final rule (the “Final Rule”) amending CFIUS’s...more

11/25/2024 / CFIUS , Foreign Investment , National Security , Real Estate Transactions , U.S. Treasury

The Commerce Department expands and clarifies the controls in the October 2023 Semiconductor Rules

The Department of Commerce’s Bureau of Industry and Security published an interim final rule to expand, correct, and clarify the two interim final rules published on October 25, 2023 with respect to semiconductor...more

4/17/2024 / Bureau of Industry and Security (BIS) , ECCNs , Export Controls , Exports , Interim Final Rules (IFR) , U.S. Commerce Department

US intensifies export control restrictions on semiconductor and supercomputing activities

The Department of Commerce’s Bureau of Industry and Security issued two interim final rules to expand on the 7 October 2022 restrictions aimed at denying access to certain advanced semiconductors, semiconductor manufacturing...more

10/24/2023 / Bureau of Industry and Security (BIS) , ECCNs , Export Administration Regulations (EAR) , Export Controls , Exports , Interim Final Rules (IFR) , National Security , Semiconductors , U.S. Commerce Department

Aerospace & Defense Insights | DDTC outlines expectations for global compliance

Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more

3/3/2023 / Aerospace , Compliance , Directorate of Defense Trade Controls (DDTC) , Export Administration Regulations (EAR) , Export Controls , ITAR , Office of Foreign Assets Control (OFAC) , Technology

CFIUS Q4 Developments

In the fourth quarter of 2020, the major CFIUS development was the significant revision of one of CFIUS’s two mandatory filing programs. Specifically, on 15 September 15 2020, the Department of Treasury (the Treasury) issued...more

12/23/2020 / CFIUS , Critical Infrastructure Sectors , Exports , Filing Requirements , Foreign Investment , Licensing Rules , Regulatory Requirements , U.S. Treasury

Josh Gelula

Hogan Lovells

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