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Foreign Adversaries

Pillsbury Winthrop Shaw Pittman LLP

DOJ Releases Its Data Security Program Compliance Guide

The guide outlines the requirements of a newly implemented Data Security Program designed to prevent China, Russia and other foreign adversaries designated by the U.S. Department of Justice from accessing American’s sensitive...more

Baker Donelson

DOJ Issues Additional Guidance and Clarification on the Bulk Data Transfer Rule: What U.S. Businesses Need to Know

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On April 11, 2025, the Department of Justice's National Security Division (NSD) issued additional guidance to assist U.S. organizations in understanding and complying with the Data Security Program (DSP). As discussed in our...more

Troutman Pepper Locke

Inside New Commerce Tech Restrictions: Key Risk Takeaways

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The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward. Originally...more

Troutman Pepper Locke

Foreign Influence in Universities Targeted by Trump Administration

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As part of the “America First” Investment Policy Memorandum, released on February 21, the Trump administration signaled that it may increase restrictions on investments made by American university endowments relating to...more

Guidepost Solutions LLC

America First Investment Policy: Navigating the Shift in CFIUS Mitigation

Every new presidential administration brings with it a degree of uncertainty regarding potential shifts in the Committee on Foreign Investment in the United States (CFIUS) process. This is especially true in our current...more

Brownstein Hyatt Farber Schreck

Trump Administration Sets Foreign Investment Goals Under the "America First Investment Policy"

On Feb. 21, 2025, President Trump issued a National Security Presidential Memorandum (NSPM) introducing an “America First Investment Policy,” which sets the stage for a significant realignment of U.S. investment regulations....more

Wiley Rein LLP

President Trump Announces “America First Investment Policy” to Promote Investments from Allies and Enhance Restrictions on China

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On February 21, 2025, President Trump signed a National Security Presidential Memorandum (NSPM) announcing an “America First Investment Policy” focused on promoting foreign investment in the United States from allies and...more

Orrick, Herrington & Sutcliffe LLP

White House to Expand Restrictions on Chinese Investment While Streamlining Investment Reviews for Allies

On February 21, 2025, a Presidential Memorandum, “America First Investment Policy” (the “Memorandum”), announced planned changes to the Committee on Foreign Investment in the United States (“CFIUS”) and outbound investment...more

Akin Gump Strauss Hauer & Feld LLP

America First Investment Policy (Trump EO Tracker)

This memorandum directs the U.S. government to use all necessary legal instruments, including the Committee on Foreign Investment in the United States (CFIUS), to restrict PRC-affiliated persons from investing in U.S....more

Latham & Watkins LLP

White House Issues America First Investment Policy

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The policy memo aims to preserve an open investment environment as well as restrict investment in strategic sectors. Late on Friday, February 21, 2025, the White House released its “America First Investment Policy”...more

Troutman Pepper Locke

Do You Know Where Your Data Is Going? On April 8, New National Security Rules Take Effect

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A groundbreaking new regulatory regime, imposing rules unlike any in existing U.S. law, may surprise many companies due to its sudden adoption and complexity. This article tries to simplify the changing regulatory landscape,...more

Holland & Knight LLP

Executive Order: Declaring a National Emergency at the Southern Border of the United States

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Date Issued: Jan. 20, 2025 This executive order declares a national emergency at the southern border of the U.S. due to the presence of threats, including cartels, criminal gangs, known terrorists, human traffickers,...more

Fox Rothschild LLP

Executive Orders to Watch for Federal Contractors and Fund Recipients

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President Trump signed a multitude of Executive Orders (EOs) during his first two weeks in office. EOs are directives from the President to federal agencies that do not require Congressional approval. EOs include mandates...more

Holland & Knight LLP

President Trump's Executive Order Halts TikTok Ban

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President Donald Trump on Jan. 20, 2025, signed an Executive Order (E.O.), Application of Protecting Americans from Foreign Adversary Controlled Applications to TikTok, halting the recently issued ban on the TikTok app (Act)...more

Morrison & Foerster LLP - Government...

Biden’s Final Cybersecurity Order Proposes Significant Changes, All to Be Implemented by the Incoming Administration

Citing the threats posed by foreign adversaries and criminal organizations, and seeking enhanced accountability for companies that provide software and cloud services to the federal government, the Biden administration has...more

Morrison & Foerster LLP

Commerce Rings in New Year with Proposed Rulemaking on Drones

The Department of Commerce (Commerce) Office of Information and Communications Technology and Services (OICTS) has broad authority—born out of executive action during the first Trump administration—to identify and mitigate...more

DarrowEverett LLP

Vibe Check on TikTok: Legal Changes May Force App to Take the L

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The future of TikTok is on the table in the United States. As has been widely covered, in April 2024, Congress passed the Protecting Americans from Foreign Adversary Controlled Applications Act (the “Act”), which...more

Ropes & Gray LLP

New Year, New Threats: Practical Tips for Secure Communications after Salt Typhoon

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As a recent DataPhiles post explored, the threat to telecommunications infrastructure and private call records posed by foreign threat actors only continues to grow. In fact, at least one U.S. government agency has urged...more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

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On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

Wiley Rein LLP

NDAA Provisions Impacting Government Contractors and Their Supply Chains

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On December 18, 2024, the Senate passed the National Defense Authorization Act for Fiscal Year 2025 (NDAA), which the House of Representatives passed the previous week. President Biden is expected to sign the bill into law...more

Morgan Lewis

Securing the ICTS Supply Chain: Commerce Issues Final Rules Pursuant to EO 13873

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The US Department of Commerce (Commerce or DOC) on December 6, 2024 issued a final rule codifying its framework for reviewing Information and Communications Technology and Services (ICTS) transactions under Executive Order...more

Vinson & Elkins LLP

Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software

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On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more

Mintz - ML Strategies

Crunch Time for BIOSECURE Act

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As the 118th Congress winds down, the House and Senate are in the throes of negotiating several packages of legislation before leaving Washington for Christmas recess. A bill to fund the government beyond December 20, a...more

Husch Blackwell LLP

State Restrictions on Foreign Land Investment: What Renewable Energy Developers and Financing Parties Should Know

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Renewable energy developers and financing parties are likely aware of the Agricultural Foreign Investment Disclosure Act (“AFIDA”), a federal law requiring disclosure of foreign investment in agricultural land. Increasingly,...more

ArentFox Schiff

As the (Customs and Trade) World Turns: November 2024

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Welcome to the November 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

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