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Treasury’s Outbound Investment Security Program Focusing on China Is in Effect (for Now)

Treasury’s final rule implementing its outbound investment regime went into effect on January 2, 2025. The final rule implemented Executive Order (E.O.) 14105 of August 9, 2023, which declared a national emergency to address...more

New HSR Act Size-of-Transaction Increasing to $126.4 Million

On January 10, 2025, the Federal Trade Commission (FTC) published its adjusted reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR Act). The FTC revises the HSR Act thresholds...more

FTC Announces Record $5.6 Million Gun-Jumping Fine and Reminds Parties of Perils of Prematurely Transferring Beneficial Ownership...

On January 7, 2025, the Federal Trade Commission (FTC) announced a proposed settlement for crude oil producers XCL Resource Holdings, LLC; Verdun Oil Company; and EP Energy LLC to pay a record-breaking $5.6 million civil...more

HSR Final Rules and Forms Substantially Revised — Considerations Ahead of the Anticipated January Effective Date

When the Federal Trade Commission (FTC) — with the concurrence of the Antitrust Division of the Department of Justice (DOJ) — published the Notice of Proposed Rulemaking to revise the rules for premerger notification under...more

New HSR Act Size-of-Transaction Increasing to $119.5 Million; Filing Fee Increases Going Into Effect Soon

On January 22, 2024, the Federal Trade Commission (FTC) published its adjusted reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR Act). The FTC revises the HSR Act thresholds...more

48C Qualified Advanced Energy Project Tax Credit: One Year Into the Inflation Reduction Act

The Inflation Reduction Act (IRA) recently celebrated its first anniversary with some programs becoming increasingly oversubscribed even before the funding is released. One of those programs is the qualifying advanced energy...more

China Enacts Updated Counterespionage Law, Increasing Risks for Multinationals Operating in China

On July 1, 2023, an amendment to the Counterespionage Law of the People’s Republic of China (2014) (2023 Amendment) took effect, following adoption by the Standing Committee of the 14th National People’s Congress of the...more

Proposed HSR Rules Upend M&A and Merger Control Review

On June 27, 2023, the Federal Trade Commission (FTC), in collaboration with the Department of Justice (DOJ) Antitrust Division, announced proposed changes to the Hart-Scott-Rodino (HSR) filing and notification form that...more

Amendment to China’s Merger Control Rules: Implications on M&A Deals

Following the August 1, 2022, amendment of the People’s Republic of China’s (PRC) Anti-Monopoly Law, the State Administration for Market Regulation — the PRC’s antitrust authority (AMR) — released the Provisions on the Review...more

G-7 Summit Kicks Off With New Russian Sanctions

As the 49th Group of Seven (G7) Summit gets underway in Japan, the United States, in coordination with several other G7 members, marked the occasion to announce sweeping new sanctions and export controls aimed at “further...more

Merger Filing Fee Modernization Act of 2022 Introduces Changes to HSR Filing Fee Structure and New Foreign Subsidy Disclosure...

Tucked into the Consolidated Appropriations Act that President Biden signed in late December was the Merger Filing Fee Modernization Act of 2022 (Filing Fee Modernization Act). The Filing Fee Modernization Act makes...more

FTC Publishes Revised HSR Thresholds for 2022

On January 24, 2022, the Federal Trade Commission (FTC) published its adjusted reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR Act) in the Federal Register. The FTC revises...more

Biden Administration Completes its Second 50 Days With Continued Pressure on Targeted Countries Using Increased Sanctions and...

The Biden administration continues to utilize United States trade sanctions and export controls as a key tool in its efforts to put pressure on China, Myanmar/Burma and Russia. Since our last update, actions by the U.S....more

Sanctions Update – The First 50 Days

In its first 50 days, the Biden administration has been busy utilizing sanctions and export controls to support its foreign policy priorities of human rights, multilateralism and support for democratic regimes. The U.S....more

FTC Publishes Decreased Hart-Scott-Rodino Thresholds for 2021

On February 2, 2021, the Federal Trade Commission (FTC) published its adjusted reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR Act) in the Federal Register. The revised thresholds,...more

Hart-Scott-Rodino and Merger Control in the Time of COVID-19

COVID-19 (commonly known as the coronavirus) has now spread to the premerger antitrust review process for reportable proposed acquisitions, investments, joint ventures and nonprofit membership changes. ...more

New General License Reopens Flow of Agricultural Commodities, Medicines and Medical Devices to Iran

On September 20, 2019, the world changed for many exporters of agricultural commodities, medicines and medical devices. Previously, those items had been authorized for export to Iran pursuant to a humanitarian general license...more

How the Coronavirus May Impact Your Commercial Health and Contracts

The recent coronavirus outbreak not only poses potential human health concerns but also raises new risks for companies engaged in trade with China. The outbreak has prompted all levels of the Chinese government to take...more

FTC Releases New Hart-Scott-Rodino Thresholds for 2020

On January 28, 2020, the Federal Trade Commission (FTC) published adjusted reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR Act) in the Federal Register. Companies...more

Tariffs – The Next Chapter: U.S.-China Trade War Reaches a Crossroads at G-20 Summit

All eyes will be on President Donald Trump and Chinese President Xi Jinping this week when the two leaders meet on the sidelines of the G-20 summit in Osaka, Japan. Both sides have indicated a willingness to re-engage on...more

U.S. Companies to Face New Challenges in China Following Creation of Unreliable Entity Regime

U.S. companies could face new headaches in the escalating U.S.-China trade war due to China’s forthcoming “unreliable entity list,” recently announced by the Ministry of Commerce of China (MOFCOM) in response to an Executive...more

Common Pitfalls and Practical Advice for Entering a Joint Venture in China

When exploring a joint venture (JV) with a Chinese partner, it is important to consider the legal and cultural differences that may contribute to the success or delay of your project. Below are some common risks associated...more

FTC Increases Hart-Scott-Rodino Transaction Thresholds for 2019

On February 15, 2019, the Federal Trade Commission (FTC) published adjusted reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR Act). Companies contemplating a merger should...more

U.S. and European Loan Markets: Comparative Approach to Sanctions Provisions

Economic sanctions, when imposed by a regime, have the purposes of advancing national security, foreign policy or economic goals. Sanctions can take multiple forms, including restrictions on investment, restrictions on trade,...more

When Does Your Transaction Require a Hart-Scott-Rodino Filing? FTC Announces Adjusted Thresholds for 2018

On January 29, the Federal Trade Commission (FTC) published increased reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR Act). The new thresholds represent an approximate 4...more

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