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The U.S. Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPRM”) to implement Executive Order 14105 (“EO 14105”) “Addressing United States Investments in Certain National Security Technologies...more
Last week, the Secretary of the Treasury released a final proposed rule to implement the Biden administration’s August 2023 Executive Order on outbound investments. The proposed rule seeks to “prevent countries of concern...more
On June 21, 2024, the Treasury Department released long-expected proposed regulations to curtail investments by U.S. persons (including investments by U.S. limited partners in non-U.S. pooled funds) and U.S.-controlled...more
On Friday, November 6, 2020, the Commerce Department’s Bureau of Industry & Security (BIS) issued a Notice of Proposed Rulemaking (NPRM) seeking public comment regarding newly-proposed controls on certain software for...more
The U.S. Department of the Treasury (“Treasury”) recently published a proposed rule that would modify the mandatory filing requirements in place throughout the pilot program for certain foreign investment transactions subject...more
President Trump signed into law the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”) on August 13, 2018, which made several substantial changes to the CFIUS process and expanded the scope of the Committee’s...more
Since the beginning of 2020, the U.S. Department of the Treasury (Treasury) has issued numerous regulations to implement fully the Foreign Risk Review Modernization Act of 2018 (FIRRMA) on behalf of the Committee on Foreign...more
- On May 21, 2020, Treasury published a Proposed Rule to align the CFIUS mandatory filing framework for transactions involving critical technologies with existing export-licensing requirements. - Under the Proposed Rule,...more
My VC Fund has U.S. and non-U.S. General Partners, will I need to file CFIUS declarations for every investment I want to make in tech, in infrastructure, or in a company with customers’ personal data? This is a critical...more
On September 17, 2019, the Department of the Treasury issued long-awaited proposed rules implementing many of the provisions of the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA"), which substantially...more
The Committee on Foreign Investment in the United States (CFIUS) last week added considerable teeth to its powers through draft regulations implementing key provisions of the Foreign Investment Risk Review Modernization Act...more
On September 17, 2019, the Committee on Foreign Investment in the United States ("CFIUS" or the "Committee") published proposed rules (the "Proposals"). The Proposals would significantly expand CFIUS' jurisdiction but only...more
On September 17, 2019, the Committee on Foreign Investment in the United States (“CFIUS”) published two Proposed Rules to implement most of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). CFIUS is an...more
On January 20, 2017, businessman Donald J. Trump was sworn in as the 45th President of the United States following a contentious and unconventional 2016 presidential election. Republicans also successfully maintained control...more