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US Trade Controls Against China Reach Supply Chain and End-Use Targets and Activities

Supply chain, end use, and human rights–related sanctions, export controls, and Entity List designations target public and private entities in China. Human rights–related designations - The US government has...more

Updated DOJ Guidance on Corporate Compliance Programs Emphasizes Technology, Real-Time Compliance Data, and Lessons Learned

The guidance provides insights for corporations seeking to develop and implement a best-in-class compliance program. On June 1, 2020, the US Department of Justice (DOJ) issued updated guidance (Updated Guidance) regarding...more

CFIUS Annual Report: 6 Key Takeaways for Calendar Year 2018

CFIUS continued to have a busy year in 2018, and CFIUS reveals first available data about the declaration process under the new Pilot Program. On May 16, 2020, the Committee on Foreign Investment in the United States...more

New CFIUS Filing Fees Now in Effect: 5 Key Takeaways

The new filing fees can be as high as $300,000 for covered transactions valued at $750 million or more. On April 27, 2020, the US Treasury Department announced in an interim rule with request for comments that the Committee...more

Final CFIUS Regulations Implementing FIRRMA Take Effect in February 2020: 10 Key Questions Answered

Under the final regulations, CFIUS filings for certain transactions will be required, and CFIUS will have broader jurisdiction to review certain foreign investments. On January 13, 2020, the US Treasury Department published...more

Department of Justice Revises Policy Regarding Voluntary Disclosures of Export Control and Sanctions Violations

The revised policy both clarifies and expands DOJ’s prior disclosure guidance. On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more

CFIUS Annual Report: 10 Key Takeaways for Calendar Years 2016 and 2017

The number of CFIUS notices filed is growing, more cases are extending into an investigation phase, and instances of pulling and refiling CFIUS notices are increasing. On November 22, 2019, the Committee on Foreign...more

US Treasury Department Publishes Proposed Regulations to Implement FIRRMA: 10 Key Questions Answered

CFIUS has offered a one-month comment period for proposed rulemaking to implement provisions of CFIUS legislation passed in August 2018. More than a year ago, in August 2018, US President Donald Trump signed the Foreign...more

CFIUS Pilot Program Makes Notifications Mandatory for Specific Areas of Critical Technology

Program requires parties to submit to CFIUS notice of certain foreign investments in US businesses involved in specified critical technologies at least 45 days prior to closing. Key Points: ..The US Treasury Department...more

New Law Governing Foreign Direct Investment in the United States Brings Significant Changes to CFIUS Review

New law expands CFIUS’ jurisdiction and brings important procedural changes to foreign direct investment review. Key Points: ..The new legislation extends CFIUS’ jurisdiction to cover non-controlling investments in the...more

Status of CFIUS Reform Legislation

New Legislation to Reform the Committee on Foreign Investment in the United States Remains a Strong Possibility Key Points: ..Reform legislation sponsors appear willing to address some concerns with the original...more

CFIUS Reconstructed: The Foreign Investment Risk Review Modernization Act of 2017

The proposed Foreign Investment Risk Review Modernization Act would bring substantial changes to CFIUS review. Key Points: ..FIRRMA could speed review of certain transactions. ..It would provide for increased...more

10 Takeaways From the CFIUS Annual Report to Congress

Calendar Year 2015 CFIUS Report reflects review of transactions for national security risks is generally taking longer, with Chinese investors leading all others. The Committee on Foreign Investment in the United States...more

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