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US Treasury Creates the ‘Reverse CFIUS’ Program, a (Limited) Great Wall on Outbound Investment

The Department of the Treasury (Treasury) has released a final rule imposing restrictions on U.S. outbound investment in Chinese companies active in developing certain national security technologies (Final Outbound Rule)....more

How Defense Contractors Can Prepare Now for CMMC Implementation

The Department of Defense (DoD) is currently reviewing and adjudicating the public comments received in response to its proposed regulations implementing its Cybersecurity Maturity Model Certification 2.0 program (CMMC)....more

Declassified: DoD Extends Its Vetting of Foreign-Owned and -Controlled Contractors To Cover Some Unclassified Contracts

Over its 30-year history, the Department of Defense (DoD) National Industrial Security Program Operating Manual (NISPOM), which establishes policies and procedures for mitigating foreign ownership, control or influence (FOCI)...more

CFIUS Proposes Expanded Real Estate Jurisdiction

On July 8, 2024, the U.S. Department of the Treasury (Treasury) issued a Notice of Proposed Rulemaking (NPRM) which, if implemented, would expand the U.S. geographical areas in which the Committee on Foreign Investment in the...more

One Step Closer to a Limited ‘Reverse CFIUS’ Program

On June 21, 2024, the U.S. Department of the Treasury announced a proposed rule (Proposed Rule) to impose limited restrictions on certain outbound U.S. investments in technology, as directed by Executive Order 14105....more

US Announces New Tariffs on Chinese-Origin Goods, With an Exclusion Process

On May 14, 2024, President Joe Biden announced that he had directed the Office of the U.S. Trade Representative (USTR) to add or increase tariffs on a range of goods originating from China, including electric vehicles (EVs),...more

CFIUS’ Proposed Rule: More Questions, Tighter Time Frames and Higher Penalties

On April 15, 2024, the secretary of the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS or Committee), published a notice of proposed rulemaking (Proposed Rule) to...more

A Fracturing Data Environment: Executive Order Portends Major Changes to US Data Management

On February 28, 2024, President Biden issued Executive Order 14117 (the EO) on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern” that would...more

2024 Insights: Other Regulatory Developments

AI in 2024: Monitoring New Regulation and Staying in Compliance With Existing Laws Companies that develop or employ AI tools have to consider proposed AI-specific regulation as well as an array of existing IP, privacy,...more

‘Small Yard and High Fence’: US National Security Restrictions Will Further Impact US-China Trade and Investment Activity in 2024

The economic relationship between China and the U.S. remains one of the most significant in the world, and U.S. and Chinese government leaders have repeatedly signaled their intent to maintain stable trade and commercial...more

AI in 2024: Monitoring New Regulation and Staying in Compliance With Existing Laws

Key Points The rapid adoption of artificial intelligence (AI) technology across the economy has raised a number of novel legal issues. In this article, we discuss five key issues to track in 2024, including:...more

Casting a Wider Net: Further Expansion of UFLPA Enforcement

The Uyghur Forced Labor Prevention Act (UFLPA) enforcement landscape continues to evolve, as evident in several recent developments: On October 24, 2023, the Congressional-Executive Commission on China (the Commission)...more

BIS Updates October 2022 Semiconductor Export Control Rules

On October 17, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released two interim final rules to reinforce and expand controls on (a) advanced semiconductors and related computing items (the...more

Federal Report Proposes Harmonization of Divergent Cyber Incident Reporting Regimes

On September 20, 2023, the U.S. Department of Homeland Security released a report outlining the varied and sometimes conflicting reporting requirements that private entities face when they are victims of a cyber incident. The...more

Privacy & Cybersecurity Update - September 2023

In this month’s Privacy & Cybersecurity Update, we examine Delaware’s new comprehensive data privacy law, a joint statement by 12 data protection authorities on data scraping and data protection, a district court ruling on a...more

Privacy & Cybersecurity Update - August 2023

In this month’s Privacy & Cybersecurity Update, we analyze the Biden administration’s proposed cybersecurity labeling program for smart devices, NIST’s extensive overhaul of its cybersecurity framework, and data privacy law...more

US Government Updates Forced Labor Strategy, Expands UFLPA Entity List

Over the past few weeks, the interagency Forced Labor Enforcement Task Force (FLETF) has signaled a shift in its strategy for enforcing the Uyghur Forced Labor Prevention Act (UFLPA). On July 26, 2023, the FLETF issued its...more

US Moves To Narrowly Limit Investment in China

On August 9, 2023, after more than a year of deliberations, the Biden administration finally released an executive order (the Order) directing the Department of the Treasury (Treasury) to create a new regulatory program to...more

Privacy & Cybersecurity Update - July 2023

In this month’s Privacy & Cybersecurity Update, we examine the newly established data privacy framework between the EU and U.S. and new consumer privacy laws in Oregon and Texas. We also review a court ruling that delayed...more

Privacy & Cybersecurity - June 2023

In our June Privacy & Cybersecurity Update, we review new data privacy laws in Colorado, Connecticut, Florida and Montana; Verizon’s annual Data Breach Investigations Report; AM Best’s report on cyber insurance trends; and...more

Privacy & Cybersecurity Update - May 2023

In this month’s Privacy & Cybersecurity Update, we review new consumer privacy laws in Tennessee and Indiana, three GDPR rulings by the Court of Justice of the European Union, updates regarding future California Privacy...more

Privacy & Cybersecurity Update - March 2023

In this month’s Privacy & Cybersecurity Update, we examine Iowa’s new data privacy law (the sixth state to enact a privacy law), the Biden administration’s new national cybersecurity strategy, the U.K. government’s revised...more

US Commerce Department Expands Export Restrictions Targeting Russia and Belarus

On February 24, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced four new rules expanding restrictions on exports to Russia and Belarus. The revisions to the Export Administration...more

Mandatory BEA Filing for Many US Businesses With Foreign Shareholders

The Bureau of Economic Analysis (BEA) within the U.S. Department of Commerce collects and publishes data regarding the U.S. economy and the status of foreign investment. As part of this mission, it conducts regular, periodic...more

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