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U.S. Treasury Department Issues Proposed Rulemaking for Forthcoming Outbound Investment Program

The outbound investment program will affect U.S. persons considering certain investments or other transactions involving China and specific industry sectors (e.g., semiconductors, artificial intelligence and quantum...more

Treasury Amends the Cuban Assets Control Regulations to Support Cuban Citizens and Independent Private Sector Entrepreneurs

On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to better implement the Biden-Harris Administration’s policy aimed at...more

Treasury Announces Proposed Rule to Update CFIUS Regulations and Bolster Enforcement

On April 11, 2024, the U.S. Department of the Treasury (Treasury), as Chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM), which is the first substantive...more

DaVinci Payments Settlement with OFAC Reveals Critical Compliance Lessons

On November 6, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced a $206,213 settlement with Swift Prepaid Solutions, Inc. d/b/a daVinci Payments (daVinci) for apparent violations of...more

Recent Updates on Foreign Investment Restrictions and Export Controls Governing Semiconductors, Quantum Computing and Artificial...

Secretary Raimondo announced that the United States will not be compromising with China on “matters of national security” in response to calls to reconsider the recent Executive Order directing the Department of Treasury to...more

Long-Awaited Executive Order on Outbound Investment Issued: Regulatory Comment Process Commences in Advance of Implementation of...

On August 9, 2023, President Biden issued an Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. The new Executive Order (EO) is the...more

Russia Invades and the West Reacts: U.S. Government Intensifies Sanctions and Export Controls Against Russia

On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have...more

Biden Administration Updates Framework for China-Related Investment Prohibitions and Expands the Scope of Restricted Chinese...

E.O. 14032 signals that the Biden Administration will continue to restrict U.S. investments into China’s defense and surveillance technology sectors. The prior Administration’s November 2020 Executive Order (E.O.) 13959...more

CFIUS Issues Final Rule Basing Mandatory Declaration Requirement on U.S. Export Control Criteria

On September 15, 2020, the U.S. Department of Treasury published a final rule that removes the mandatory declaration requirement for filings to the Committee on Foreign Investment in the United States (CFIUS) based on North...more

CFIUS Unveils Proposed Rule to Impose Filing Fees

On March 5, 2020, the U.S. Department of the Treasury issued a proposed rule establishing filing fees for parties submitting a voluntary notice to the Committee on Foreign Investment in the United States (CFIUS) for “covered...more

Treasury Department Designates Russian Oligarchs, Officials, and Entities

The Treasury Department has placed several prominent Russian individuals and companies on the Specially Designated Nationals and Blocked Persons lists (“SDN list”). Several of these parties are Russian billionaires previously...more

FinCEN Proposes to Regulate Investment Advisers under the Bank Secrecy Act

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015 which, among other things, would add SEC-registered investment advisers to the “financial...more

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