News & Analysis as of

Foreign Adversaries Committee on Foreign Investment in the United States U.S. Commerce Department

Morrison & Foerster LLP

Commerce Issues First-Ever ICTS “Final Determination” Banning Kaspersky Cybersecurity Products

On June 24, 2024, the Commerce Department published a Final Determination under its Information and Communications Technology and Services (ICTS) authorities. The determination prohibits the Russian-controlled cybersecurity...more

Wiley Rein LLP

House Select Committee on the CCP Issues Report and 150 Policy Recommendations Affecting Trade, Telecom, Government Contracts and...

Wiley Rein LLP on

Last week, the House Select Committee on the Strategic Competition between the United States and the Chinese Communist Party (Select Committee) issued a comprehensive new bipartisan report, including almost 150 policy...more

Morrison & Foerster LLP

Information and Communications Technology and Services Supply Chain Developments

On November 26, 2021, the U.S. Department of Commerce (“Commerce”) published a Proposed Rule that expanded on a prior rule implementing provisions of Executive Order 13873 on Securing the Information and Communications...more

Holland & Knight LLP

Biden Signs Executive Order to Protect Personal Data from Foreign Adversaries

Holland & Knight LLP on

The U.S. government's efforts to secure sensitive personal data against foreign adversaries, primarily with an eye toward China, continue. On June 9, 2021, President Joe Biden signed the Executive Order on Protecting...more

Wiley Rein LLP

Commerce Calls for Public Input on Licensing Procedures for ICTS Transactions Involving “Foreign Adversaries”

Wiley Rein LLP on

On March 29, 2021, the U.S. Department of Commerce (Commerce or the Department) issued an advance notice of proposed rulemaking (ANPRM) regarding new licensing procedures for Commerce’s January 2021 interim final rule for...more

Jones Day

Commerce Department Rule Authorizes Review of ICTS Transactions Involving "Foreign Adversaries"

Jones Day on

The Situation: Later this month, transactions in the information and communication technology and services ("ICTS") sector that involve designated "foreign adversaries" will be subject to review by the U.S. Department of...more

White and Williams LLP

Department of Commerce Issues New Interim Final Rule on Securing the Information and Communications Technology and Services Supply...

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n late January 2021, the U.S. Department of Commerce issued an Interim Final Rule (Interim Rule) that would empower the Department to prohibit, mitigate and unwind certain categories of transactions with certain foreign...more

Akin Gump Strauss Hauer & Feld LLP

Biden Administration Reviewing Comments on Interim Final ICTS Rule

Key Points - On January 19, 2021, the U.S. Commerce Department published an interim final rule (IFR) to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more

Husch Blackwell LLP

Commerce Publishes Interim Final Rule Addressing “Foreign Adversaries” In ICTS Supply Chain

Husch Blackwell LLP on

On January 19, 2021, the U.S. Department of Commerce (Commerce) published a long-awaited interim final rule to address the use of goods or services sourced from “foreign adversaries” in the U.S. supply chain for information...more

Pillsbury - Global Trade & Sanctions Law

Commerce Department’s New ICTS Rule Raises Additional Considerations for Cross-Border Transactions

On January 19, 2021, the Commerce Department issued an interim final rule to implement the Executive Order on Securing the Information and Communications Technology and Services Supply Chain (E.O. 13873), which was issued on...more

Husch Blackwell LLP

Commerce Department Publishes Interim Final ICTS "Foreign Adversary" Rules

Husch Blackwell LLP on

Key Point: New rules will impact the use of equipment and digital services sourced from China and other “foreign adversaries” in a wide variety of transactions and activities that potentially pose a risk to U.S. national...more

Akin Gump Strauss Hauer & Feld LLP

Commerce Issues Proposed Rule Implementing “Supply Chain Executive Order”

Key Points - On November 26, 2019, the U.S. Department of Commerce (“Commerce”) issued a proposed rule to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more

Dechert LLP

Proposed Rule Grants Broad Authority to Block Information and Communications Technology Services Transactions

Dechert LLP on

On November 27, the U.S. Department of Commerce issued a proposed rule and request for comment relating to its implementation of the May 15, 2019 Executive Order (“EO”) 13873, “Securing the Information and Communications...more

White & Case LLP

US Targets Telecommunications Transactions Involving the Information and Communications Technology and Services Supply Chain

White & Case LLP on

On May 15, 2019, President Trump issued an executive order (EO), "Executive Order on Securing the Information and Communications Technology and Services Supply Chain," prohibiting certain transactions involving...more

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