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Articles by Daniel E. Goren
DDTC Publishes ITAR Omnibus Amendments Proposed Rule
The U.S. Department of State's Directorate of Defense Trade Controls (DDTC) has proposed amendments to the International Traffic in Arms Regulations (ITAR) that would remove certain items from the U.S. Munitions List (USML), clarify several key definitions and create a new temporary export exemption.
AI Pacing Agreements: Legal Issues and Potential Strategies to Manage Them
Artificial intelligence (AI) pacing agreements – coordinated commitments among frontier AI laboratories to slow the pace of capability development until safety research catches up – raise significant antitrust issues under the Sherman Act because they can be characterized as competitor agreements to restrict output or slow innovation.
AI Pacing Agreements: Legal Issues And Potential Strategies To Manage Them
Artificial intelligence (AI) pacing agreements – coordinated commitments among frontier AI laboratories to slow the pace of capability development until safety research catches up – raise significant antitrust issues under the Sherman Act because they can be characterized as competitor agreements to restrict output or slow innovation.
Key Takeaways From The CFIUS Annual Report For Calendar Year 2025
HK Holland & Knight More Holland & Knight is a global law firm with nearly 2,000 lawyers in offices throughout the world. Our attorneys provide representation in litigation, business, real estate, healthcare and governmental law. Interdisciplinary practice groups and industry-based teams provide clients with access to attorneys throughout the firm, regardless of location.
Key Takeaways from the CFIUS Annual Report for Calendar Year 2025
Short-form "declarations" were parties' filing of choice more than half the time, but declaration clearance rates fell to an all-time low of 66 percent. The Committee on Foreign Investment in the U.S. (CFIUS) continued to reduce its use of mitigation agreements, consistent with one of the goals of the Trump Administration's America First Investment Policy. Non-notified transaction monitoring remains a key priority, with thousands of non-notified transactions screened for potential review.
DOJ's National Security Division Issues First Declination Under New Corporate Enforcement Policy
The U.S. Department of Justice's (DOJ) National Security Division issued its first declination under a revised Corporate Enforcement Policy, citing a non-U.S. company's voluntary self-disclosure, full cooperation and extensive remediation efforts.
From Denial to Due Diligence: Loosening of ITAR Restrictions on Ethiopia
The U.S. Department of State's Directorate of Defense Trade Controls (DDTC) announced on May 11, 2026, that it had terminated the arms embargo on Ethiopia and ended the policy of denial under the International Traffic in Arms Regulations (ITAR) Section 126.1. ITAR license applications involving Ethiopia will now be reviewed on a case-by-case basis, and ITAR exemptions will once again be available for exports to Ethiopia.
BIS Expands Impact Of U.S. Export Controls With 50 Percent Rule
The U.S. Department of Commerce Bureau of Industry and Security (BIS) published an interim final rule, which makes foreign entities that are owned 50 percent or more by a company on the Entity List, Military End-User List or certain entities on the Specially Designated Nationals and Blocked Persons List subject to the same U.S. export control restrictions as those parent entities.
BIS Expands Impact of U.S. Export Controls with 50 Percent Rule | JD Supra
The U.S. Department of Commerce Bureau of Industry and Security (BIS) published an interim final rule, which makes foreign entities that are owned 50 percent or more by a company on the Entity List, Military End-User List or certain entities on the Specially Designated Nationals and Blocked Persons List subject to the same U.S. export control restrictions as those parent entities.
Suirui International Ordered to Divest from Jupiter Systems | JD Supra
President Donald Trump on July 8, 2025, issued a presidential order retroactively prohibiting the February 2020 acquisition of Jupiter Systems LLC, a Delaware limited liability company, by Hong Kong-based Suirui International Co. Ltd. The order requires that Suirui International divest all interests and rights in Jupiter and prohibits Jupiter from holding any interests or rights in any assets or operations of Jupiter's Asian subsidiaries acquired or formed after the acquisition.
Executive Order Terminates Syria Sanctions, Directs Actions to Remove Other Trade Restrictions | JD Supra
On June 30, 2025, President Donald Trump issued an Executive Order (the EO) terminating the U.S. government's Syria sanctions program and directing other actions that, if finalized, will revoke the vast majority of U.S. trade restrictions imposed on Syria by the U.S. government.
Executive Order Terminates Syria Sanctions, Directs Actions To Remove Other Trade Restrictions
HK Holland & Knight More Holland & Knight is a global law firm with nearly 2,000 lawyers in offices throughout the world. Our attorneys provide representation in litigation, business, real estate, healthcare and governmental law. Interdisciplinary practice groups and industry-based teams provide clients with access to attorneys throughout the firm, regardless of location.
FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags
HK Holland & Knight More Holland & Knight is a global law firm with nearly 2,000 lawyers in offices throughout the world. Our attorneys provide representation in litigation, business, real estate, healthcare and governmental law. Interdisciplinary practice groups and industry-based teams provide clients with access to attorneys throughout the firm, regardless of location.
FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags | JD Supra
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 6, 2025, published an advisory on identifying and reporting potential sanctions evasion and other suspicious activity related to Iran. The advisory provides information on frequently observed in Iranian sanctions evasion activities, as well as updated red flags related to illicit Iranian activity.
Trump Administration Provides Significant Sanctions Relief to Syria | JD Supra
The U.S. Department of the Treasury's Office of Foreign Assets Control announced a significant relaxation of the comprehensive economic sanctions imposed on Syria through the issuance of General License 25 (GL 25). The action was announced in coordination with the U.S. Department of State and Treasury Department's Financial Crimes Enforcement Network, which also announced certain actions to relax certain restrictions on trade with Syria.
President Trump Announces Intent to Lift Syria Sanctions | JD Supra
President Donald Trump, during a conference in Saudi Arabia on May 13, 2025, announced his intent to lift sanctions on Syria in order to give the nation a "fresh start." The announcement follows the fall of the Bashar al-Assad regime in December 2024 and reports of Syria's new government attempting to build ties with the U.S. and other Western nations.
Treasury Department Announces Fast-Track Pilot Program For Foreign Investors
The U.S. Department of the Treasury on May 8, 2025, announced its intent to launch a fast-track process to facilitate greater investment from allied and partner sources. The process will include the launch of a "Known Investors" portal to collect information from foreign investors in advance of a filing.
Treasury Department Announces Fast-Track Pilot Program for Foreign Investors | JD Supra
The U.S. Department of the Treasury on May 8, 2025, announced its intent to launch a fast-track process to facilitate greater investment from allied and partner sources. The process will include the launch of a "Known Investors" portal to collect information from foreign investors in advance of a filing.
Are You an Exporter? You Might Be: The Often Overlooked Controls on Software with Encryption Capacity
In a world of electronic connectivity, software with encryption capacity surrounds us. It is inside your home, masking the signal between your WiFi and your computer. It is in your car, concealing the data passed through a Bluetooth connection to the car’s audio system. It is in your office, guarding the files stored in its file management system. It is in your web-browser, protecting financial transactions with your bank. And of course, it is in your pocket, in virtually every app on your phone.
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