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Enforcement Actions National Security

Mayer Brown

CFIUS Announces $60 Million Penalty and Debuts New Enforcement Website

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On August 14, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) announced a $60 million penalty, “the largest penalty CFIUS has ever issued,” following its finding of material violations...more

Dechert LLP

Highlights from the CFIUS Annual Report

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The U.S. Department of the Treasury’s Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has published its Annual Report to Congress for 2023 (the “Annual Report”), which provides important data...more

Morrison & Foerster LLP

Key Points from the 2023 CFIUS Annual Report

On July 23, 2024, the Committee on Foreign Investment in the United States (CFIUS or the “Committee”) released its Annual Report to Congress covering calendar year 2023. In a year that featured lower deal volume, CFIUS...more

White & Case LLP

AI Watch: Global regulatory tracker - United Kingdom

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The UK prioritizes a flexible framework over comprehensive regulation and emphasizes sector-specific laws. Laws/Regulations directly regulating AI (the “AI Regulations”) The UK government's AI Regulation White Paper of...more

Guidepost Solutions LLC

Proactive Measures for Corporate Security in an Escalating Threat Environment

Given the heightened terrorism threat level, comparable to that of 9/11, and the recent assassination attempt on former President Trump, it’s crucial for corporate security to prioritize comprehensive preparedness for all...more

Robinson & Cole LLP

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

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On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

Thomas Fox - Compliance Evangelist

To the DOJ: Think Big and Go Big on the Boeing Monitorship

Perhaps the most significant blog post in the compliance arena was penned by Matt Ellis over 10 years ago when he challenged Walmart to “Go Big” on compliance. (They did.) We are now at another inflection point in compliance...more

Mayer Brown

BIS Issues First ICTS Ban, Prohibiting Sales and Updates to Kaspersky Products and Services in the US, while OFAC Sanctions Senior...

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On June 20, 2024, the Department of Commerce's Bureau of Industry and Security (BIS) issued a Final Determination (“Determination”) prohibiting Kaspersky Lab, Inc.—the US subsidiary of the Russia-based antivirus software and...more

The Volkov Law Group

Life Sciences Company Escapes Criminal Charges for Employee’s Illegal Export Scheme

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Sigma-Aldrich, Inc., d/b/a MilliporeSigma (“MilliporeSigma”), a U.S. life sciences company based in Massachusetts, escaped criminal charges for export control violations, despite a former sales person’s scheme to illegally...more

ArentFox Schiff

Investigations Newsletter: Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud...

ArentFox Schiff on

Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud Under NSD Enforcement Policy - On May 22, the US Department of Justice (DOJ) announced that it will not prosecute a...more

Orrick, Herrington & Sutcliffe LLP

CFIUS’s Proposed Regulatory Enhancements Would Increase Transactional Risks

The Committee on Foreign Investment in the United States (CFIUS) has taken another significant step in transforming from a limited jurisdiction interagency committee that primarily reviewed voluntary filings into a body with...more

American Conference Institute (ACI)

[Event] 5th Annual European Forum on Global FDI Reviews - June 11th - 12th, Ixelles, Belgium

Hosted by C5 Group, the 5th Annual European Forum on Global FDI Reviews returns for another exciting year with curated programming that provide sessions on the most pressing issues coming across your desk and strategic...more

Jenner & Block

Client Alert: FARA Unit Enters Landmark DPAs to Resolve Lobbyists’ FARA Violations

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Earlier this year, the Department of Justice’s (DOJ) Foreign Agents Registration Act (FARA) Unit entered into what appeared to be the first publicly announced deferred prosecution agreements (DPAs) to resolve alleged FARA...more

Akin Gump Strauss Hauer & Feld LLP

DOJ National Security Division Updates Corporate Crime Enforcement Policy and Issues Whistleblower Policy

Executive Summary - - On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions. - These updates follow repeated...more

Wiley Rein LLP

Wiley's 10 Key Trade Developments: Evolution of Export Controls

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Along with engaging in closer cooperation with partner countries, the U.S. is prioritizing its own national security interests as well, moving first in many respects....more

Jenner & Block

Client Alert: White House Executive Order Seeks to Protect Americans’ Sensitive Personal Data and US Government-Related Data in...

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

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

Foley Hoag LLP - White Collar Law &...

Criminal Tax Enforcement – What to Look For in 2024

IRS enforcement activity remained strong in 2023, with the volume of investigations and prosecutions initiated holding steady from 2022. Despite the substantial funding boost provided by the Inflation Reduction Act, with some...more

American Conference Institute (ACI)

[Event] 10th National Conference on CFIUS - April 11th - 12th, Arlington, VA

Hosted by American Conference Institute, the 10th National Conference on CFIUS returns for another exciting year with curated programming that will provide invaluable insights on repositioning your transaction planning amidst...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

McDermott Will & Emery

Year in Review: Criminal Enforcement by the DOJ Antitrust Division in 2023

When it comes to antitrust criminal enforcement, 2023 will be remembered as the year when the US Department of Justice’s (DOJ) Antitrust Division redefined and tested the outer boundaries of its authority. This report looks...more

Torres Trade Law, PLLC

Trade Violations Under the False Claims Act

On February 7, the U.S. Department of Justice (DOJ) announced that settlements and judgements under the False Claims Act (FCA) exceeded $2 billion for the 2022 fiscal year. The 2022 fiscal year also had the second-highest...more

Wiley Rein LLP

[Webinar] 2024 International Trade and National Security Outlook: Policies and Cases to Watch - February 15th, 1:00 pm - 2:00 pm...

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We anticipate that 2024 will be another extremely important year for international trade and national security law and policy. The Biden Administration and Congress will continue to debate trade legislation and policy...more

Sheppard Mullin Richter & Hampton LLP

For Limited Use Only: Guidance on National Security Delay Determinations under the SEC Cyber Reporting Rule

On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...more

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