News & Analysis as of

Know Your Customers National Security

Sheppard Mullin Richter & Hampton LLP

Know Thy Neighbor as Thyself: CFIUS Considerations in Commercial Real Estate Transactions

While many venture capitalists and private equity sponsors are aware the Committee on Foreign Investment in the United States (“CFIUS”) has authority to review inbound investments in certain sensitive U.S. industries, many...more

StoneTurn

The Importance of Having a National Security Strategy

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The United States and an increasing number of other countries are evaluating the impact of foreign investment on their countries’ national security posture. Generally, foreign investment regulatory regimes allow regulators to...more

Fenwick & West LLP

Latest Updates in Trade Controls for the Tech Sector

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Melissa Duffy and Trevor Coval contributed their thought leadership to the American Conference Institute’s 14th Annual Global Encryption, Cloud & Cyber Export Controls Conference, held in San Francisco on May 14-16. Melissa...more

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

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The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

Venable LLP

Nonprofits Operating Abroad: Five Key Compliance Strategies

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With the current state of the world and heightened scrutiny of the nonprofit sector, it is critical that nongovernmental organizations (NGOs) with international reach routinely assess the effectiveness of their trade...more

Morrison & Foerster LLP

BIS Proposes Rule to Address Challenges of Artificial Intelligence and Malicious Cyber-Enabled Activities

On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a proposed rule to prevent foreign actors from using U.S. cloud computing services for malicious cyber activities. The proposal...more

Polsinelli

Corporate Transparency Act – Your Beneficial Entity Ownership Disclosure Is Now Required

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Executive Summary - The U.S. Congress recently passed the Corporate Transparency Act (“CTA”) as part of the 2021 National Defense Authorization Act. The CTA requires certain corporations, limited liability companies and...more

Rothwell, Figg, Ernst & Manbeck, P.C.

FinCEN’s Proposed Rulemaking for Cryptocurrency – The Balance of National Security vs. Privacy

Just before the Christmas holidays, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rulemaking entitled “Requirements for Certain Transactions Involving Convertible Virtual...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN and Federal Reserve Propose To Significantly Lower Threshold for International Funds Transfers Under Recordkeeping and...

On October 27, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (Federal Reserve, together with FinCEN, “the Agencies”)...more

K2 Integrity

FinCEN’s Beneficial Ownership Rule and Increased AML Burden

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Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more

Morgan Lewis

Online Payment Systems Technology in China—Trojan Horse or Forbidden Fruit?

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Powerful new computational technology pioneered in e-commerce presents Chinese regulators with potential concerns and solutions to the perennial problem of information, pricing, and settlement capacity. Online payment...more

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