Everyone Come to Play: Exploring FOCI Mitigation Instruments
Podcast - FOCI Mitigation: SSAs, SCAs and Proxy Agreements
Leaders in Law: The State of International Trade with Neena Shenai
Understanding FOCI Mitigation
Podcast - Navigating M&A Due Diligence: Safeguarding Security Clearances
An In-Depth Overview of the DCSA
Ask a CFIUS Expert: Is Crypto Spying on Us?
Podcast - Change Condition Packages: Tips for Cleared Contractors
Podcast - Corporate Documents in the Context of Clearances
Decoding the Key Management Personnel Requirements
Navigating Personnel Security Clearances (PCLs)
Wiley's 10 Key Trade Developments: Outbound Investments and CFIUS Review
What Is an FCL and How Do I Obtain One?
AGG Talks: Cross-Border Business - How Foreign Companies Can Protect Their IP and Brand in the U.S.
Emerging Technology in the FY24 NDAA
John Neiman on the Corporate Transparency Act
Wiley's 10 Key Trade Developments: Evolution of Export Controls
FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion
AGG Talks: Cross-Border Business - Privacy & Cybersecurity Considerations for Non-U.S. Companies
Video: Making Trade Inclusive for All Americans: A Conversation with SAP's Michelle Trong Perrin-Steinberg
The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...more
Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more
On June 20, the Department of Commerce’s Bureau of Industry and Security (BIS) for the first time banned a software and cybersecurity company using authority provided by June 2023’s “Protecting Americans’ Sensitive Data from...more
The Notice of Proposed Rulemaking (NPRM or the Proposed Rule), issued by Treasury on June 21, 2024, would implement President Biden’s August 9, 2023, Executive Order on outbound investment, which addresses concerns related to...more
On April 11, 2024, the U.S. Department of the Treasury issued a Notice of Proposed Rulemaking (NPRM) proposing a new rule updating the mitigation and enforcement provisions of the regulations administered by the Committee on...more
Secretary Raimondo announced that the United States will not be compromising with China on “matters of national security” in response to calls to reconsider the recent Executive Order directing the Department of Treasury to...more
In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national...more
The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more
On July 26, 2023, the U.S. Departments of Justice, Treasury, and Commerce issued a joint compliance note (“JCN”) regarding voluntary self-disclosure (“VSD”) policies that apply to potential violations of U.S. sanctions...more
On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more
The US Senate approved an amendment to the National Defense Authorization Act adding mandatory notifications of certain outbound investments in certain countries, including the People’s Republic of China....more
On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more
On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
On July 26, 2023, the Department of Justice (“DOJ”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published their second...more
On Thanksgiving of 2014, I received an urgent call asking me to be in London in 24 hours. My assignment was to run the advanced forensics recovery team serving several foreign offices of Sony Pictures in the wake of a...more
The U.S. government continues to increase scrutiny over certain foreign investments in the United States and critical supply chain security. On 15 September 2022, President Biden signed the “Executive Order on Ensuring Robust...more
1. Updates to Russia Sanctions and Export Controls- In response to the ongoing attack on Ukraine, the U.S. government continues on a weekly basis to increase economic sanctions and export controls on Russia. ...more
The U.S. Department of the Treasury (Treasury), which chairs the Committee on Foreign Investment in the United States (CFIUS or the Committee), recently announced several actions pertaining to its mandate under the Foreign...more
On October 28, 2021, a bipartisan group of U.S. Senators introduced the Food Security is National Security Act of 2021 (the “Act”). Among other things, the Act would require the Committee on Foreign Investment in the United...more
1. New Cybersecurity Export Controls From BIS Go Into Effect in January - The Bureau of Industry and Security (BIS) has released an interim final rule establishing new export controls on certain cybersecurity items and...more