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China Boosts Enforcement of Anti-Foreign Sanctions Law

China has recently taken several actions showing its commitment to counter trade restrictions imposed by other countries. In March 2025, it released regulations implementing the 2021 Anti-Foreign Sanctions Law. In tandem with...more

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

New Export Control Rule Regulates Global Diffusion of Artificial Intelligence

The U.S. Commerce Department's Bureau of Industry and Security ("BIS") issued a rule establishing a framework to prevent U.S. adversaries from accessing the most advanced artificial intelligence ("AI") systems while...more

Immutable Code Is Not Property: Fifth Circuit Reverses Tornado Cash Sanctions Ruling

The United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control ("OFAC") exceeded the authority granted by the International Emergency Economic Powers Act ("IEEPA") when it added the...more

CFIUS Annual Report Touts an Increase in Penalties and Efficiency in Transaction Reviews

While the total number of filings declined in comparison to recent years, CFIUS's latest Annual Report to Congress highlights an uptick in penalties and an increased use of enforcement tools relating to national...more

Treasury Proposes Expansion of CFIUS Real Estate Review Authority

On July 8, 2024, the U.S. Department of the Treasury ("Treasury") issued a proposed rule to expand the Committee on Foreign Investment in the United States' ("CFIUS") jurisdiction over certain categories of foreign investment...more

Treasury Department Unveils Long-Anticipated Proposed Regulations for U.S. Outbound Investment Regime

The Situation: On June 21, 2024, the U.S. Department of the Treasury ("Treasury") issued a notice of proposed rulemaking to implement President Biden's executive order mandating national security review of certain U.S....more

U.S. Ban on Imports of Russian Uranium Opens Door to Domestic Production

On May 13, 2024, President Biden signed into law the Prohibiting Russian Uranium Imports Act ("the Act"), which bans imports of low-enriched uranium ("LEU") produced in Russia or by a Russian entity. The Act will go into...more

CFIUS Signals Enhanced Enforcement Focus With New Proposed Changes to Regulations

On April 11, 2024, the Treasury Department announced a prepublication copy of a proposed rule amending the regulations of the Committee on Foreign Investment in the United States ("CFIUS") (the "Proposed Rule")....more

NIST Extends its Cybersecurity Framework to Cover Evolving Threats and Governance

The National Institute of Standards and Technology ("NIST") released a significant update to its framework, expanding its scope and reach to cover a broader audience and evolving cybersecurity risks and management issues....more

Executive Order Limits Sale or Transfer of Personal Data to Certain Countries

The U.S. Government has identified the exploitation of Americans' bulk sensitive personal data and U.S. government-related data by "countries of concern" as posing a national security risk....more

BIS Releases Rules to Revise and Expand Controls Relating to Semiconductors and Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") recently released two rules to update export controls on advanced semiconductors, semiconductor development and production, and items that support...more

President Biden Issues Executive Order on "Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence"

On October 30, 2023, President Biden signed a first-of-its-kind executive order entitled, "Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence" ("AI")....more

Draft Principles on Advanced Artificial Intelligence Signal Increased Efforts Toward Global Cooperation

The United States Patent and Trademark Office, along with the U.S. Departments of State and Commerce, sought initial public comment last week on draft guidelines entitled "International Guiding Principles for Organizations...more

Biden Administration Issues Highly Anticipated Executive Order on U.S. Investment in China

The Biden administration has issued a long-anticipated executive order targeting U.S. outbound investment in certain Chinese industries; however, significant steps remain before these measures are fully implemented....more

Leading Technology Companies Agree to White House's AI Safeguards

On July 21, 2023, the White House announced that seven leading technology companies—Amazon, Anthropic, Google, Inflection, Meta, Microsoft, and OpenAI—voluntarily committed to mitigating the risks posed by artificial...more

Commerce Department Issues Final Rule on Information and Communications Technology Supply Chain

On June 16, the U.S. Department of Commerce published a final rule, effective July 17, 2023, on Securing the Information and Communications Technology and Services ("ICTS") Supply Chain, signaling potential new actions on...more

Senate Hearings Signal Bipartisan Drive for AI Regulation

In Short - The Situation: Rapid advances in generative artificial intelligence ("AI") have galvanized bipartisan support for a new U.S. legal framework to regulate AI, potentially including creation of a new federal...more

California Takes Significant Step Towards Reforming CEQA and Streamlining Infrastructure Projects

On May 19, 2023, California Governor Gavin Newsom unveiled a significant legislative package and signed an executive order aimed at reforming the California Environmental Quality Act ("CEQA") and streamlining infrastructure...more

Commerce Publishes Proposed Rule Setting Conditions for Use of CHIPS Funding

In Short - The Situation: The U.S. Department of Commerce ("Commerce") recently published a proposed rule to implement the Creating Helpful Incentives to Produce Semiconductors ("CHIPS") Act, a domestic manufacturing...more

Better Together: U.S. and EU Enter Artificial Intelligence Collaboration Agreement

The United States and European Union recently entered into an administrative agreement to collaborate on critical research related to artificial intelligence ("AI"), focusing on five key areas of significant global concern....more

EU Proposes Corporate Criminal Penalties for Sanctions Breaches

On 2 December 2022, the European Commission proposed a new Directive aiming to unify the approach taken by its Member States to enforce European Union ("EU") sanctions and criminalize their violations (the "proposal")....more

Rising Global Regulation for Artificial Intelligence

Across multiple continents and industries, artificial intelligence ("AI") is a topic of intense focus by governments, research institutions, investors, and corporations—from start-ups to well-established industry players. As...more

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