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Articles by Jake Ely
CFIUS 2025 Annual Report
On August 7, 2026, the Committee on Foreign Investment in the United States (CFIUS) published its Annual Report to Congress covering transactions completed in calendar year 2025 (the 2025 Report). The 2025 Report confirms that CFIUS remains highly active and that well-prepared filings remain critical to getting through the review as efficiently as possible.
CFIUS 2025 Annual Report
AO A&O Shearman More A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.
The evolving landscape of Iran-related sanctions: impacts of U.S. policy shifts on international business
On July 8, 2026, U.S. President Donald Trump stated that the ceasefire agreement between the U.S. and Iran was “over.” The resumption of hostilities follows recent shifts in U.S. sanctions policy toward Iran, including a June 2026 memorandum of understanding (MoU) and OFAC’s issuance of General License X (GL X), which temporarily authorized certain transactions involving Iranian-origin oil and petroleum products.
U.S. set to impose Foreign Terrorist Organization designations on Brazil’s two largest criminal organizations
New designations The State Department designated CV and PCC as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order 13224 (“EO 13224”), effective immediately, and stated its intent to further designate both CV and PCC as Foreign Terrorist Organizations (FTOs) pursuant to Section 219 of the Immigration and Nationality Act (8 U.S.C. § 1189), effective June 5, 2026.
A&O Shearman advises Wacoal on its acquisition of Glamorise Foundations
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Wacoal is a Kyoto‑headquartered, Tokyo Stock Exchange‑listed company engaged in the design, manufacture, wholesale, and retail sale of intimate apparel, outerwear, sportswear, and related textile products, with operations across Japan, the Americas, Europe, China, and Southeast Asia. Glamorise, a century‑old U.S. brand, complements Wacoal’s core business and expands its reach into the growing inclusive‑sizing segment of the U.S. market.
By Dario De Martino, Dario de Martino, Brian Jebb, Keren Livneh, Gordon Mak, John Hibbard, Ken Rivlin, Carolyn Stoner, Iqra Anees, Roy Ji, K. J. Salameh, Elizabeth Edel, Bertrand Nzabandora, Christina Simpson, Ryan Sedwick, Jake Ely, Brendan Holman, Madhura Banerjee, Daphne Ratnarajah, Austin Grossfeld, Sarah Umstadt
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aoshearman.com
U.S. M&A rises as policy shifts drive oil and gas dealmaking
Following a surge in U.S. M&A in the second half of 2025, hope for heightened activity in 2026 are high—even with the midterm elections on the horizon. Here we explore the forces we expect to drive markets in the month to come, from the AI boom to shifts in energy policy.
A&O Shearman Advises on Deal
A&O Shearman has advised La Caisse (formerly CDPQ), a global investment group, in connection with its strategic investment in Pike Corporation (“Pike”), a leading provider of grid infrastructure services in the United States. This transaction supports grid modernization for U.S. electric utilities. La Caisse is partnering with TPG, a leading global alternative asset manager, to acquire a majority interest in Pike.
U.S. Imposes New Sanctions Targeting Two Of Russia's Largest Oil Companies
A&O Shearman are most popular: within Consumer Protection, Insolvency/Bankruptcy/Re-Structuring and Insurance topic(s) in United Kingdom On October 22, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") imposed blocking sanctions on two of Russia's largest oil companies—Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil")—and several of their subsidiaries. In this alert, we provide an overview of these measures and key takeaways.
AI diffusion rule rescinded; policy guidance for advanced integrated circuits and commodities issued | JD Supra
[co-author: Olivia Kreft] The U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced on May 13, 2025, its plans to rescind the Artificial Intelligence Diffusion Framework (the Rule), the Biden-era regulation that imposed a world-wide licensing requirement on advanced semiconductors and advanced computing commodities. Issued on January 15, 2025, the Rule was due to be enforced beginning May 15, 2025.
The EU proposes to ban Russian gas: The EU proposes phasing-out imports of Russian gas | JD Supra
In accordance with the EU’s plan to achieve full energy independence from Russia, the European Commission (“Commission”) has, on May 6, 2025, unveiled the Repower Roadmap.1Under the terms of this proposal, imports of Russian gas under new contracts and existing spot contracts would be prohibited by the end of 2025. The remaining imports of Russian gas would be prohibited by the end of 2027.
A new era of global trade tensions | JD Supra
On April 2, 2025, after weeks of speculation and heightened geopolitical tension, President Trump announced sweeping global tariffs on what he dubbed “Liberation Day”. The tariffs included a baseline universal tariff of 10% on most imported foreign goods,1 in addition to specific “reciprocal tariffs” on several major trading partners. It was initially announced that the universal tariff would go into effect on April 5, while the reciprocal tariffs were due to begin on April 9.
Trump's Reciprocal Tariff Program
AO A&O Shearman More A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.
Trump’s reciprocal tariff program | JD Supra
[co-author: Olivia Kreft] This marks the second instance in its history that IEEPA has been used to impose tariffs,1 and further builds on President Trump’s invocation of executive authority to impose tariffs on imported goods, which we discuss in greater depth in separate articles “Trump administration's tariffs targeting China, Canada and Mexico” and “Trump’s steel and aluminum tariffs.” The additional tariff duty rates in the Reciprocal Tariff EO have been introduced to address current and...
U.S. Tariffs In The Pharmaceutical Sector
Since taking office in January 2025, the Trump Administration has announced, imposed, or reimposed various tariff-related restrictions on articles imported into the United States. These proposed tariffs and their implementation have evolved rapidly and dynamically, at times with very little notice.
U.S. tariffs in the pharmaceutical sector | JD Supra
[co-author: Olivia Kreft] Since taking office in January 2025, the Trump Administration has announced, imposed, or reimposed various tariff-related restrictions on articles imported into the United States. These proposed tariffs and their implementation have evolved rapidly and dynamically, at times with very little notice.
President Trump announces “America First Investment Policy” | JD Supra
On February 21, 2025, President Trump issued a National Security Presidential Memorandum (NSPM) that sets out his administration's “America First Investment Policy,” with a particular focus on promoting foreign investment from allies and partners while seeking to address threats posed by certain foreign adversaries.
President Trump Announces "America First Investment Policy"
AO A&O Shearman More A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.
President Trump announces “America First Investment Policy”
On February 21, 2025, President Trump issued a National Security Presidential Memorandum (NSPM) that sets out his administration's “America First Investment Policy,” with a particular focus on promoting foreign investment from allies and partners while seeking to address threats posed by certain foreign adversaries.
Trump's Steel And Aluminum Tariffs
On February 10 and 11, 2025, President Trump issued two proclamations pursuant to Section 232 of the Trade Expansion Act of 1962 (Section 232) announcing the imposition and/or reimposition of certain tariffs on imported steel articles (the 2025 Steel Proclamation) and aluminum articles (the 2025 Aluminum Proclamation) into the United States (together, the 2025 Proclamations).
Trump’s steel and aluminum tariffs | JD Supra
On February 10 and 11, 2025, President Trump issued two proclamations pursuant to Section 232 of the Trade Expansion Act of 1962 (Section 232) announcing the imposition and/or reimposition of certain tariffs on imported steel articles (the 2025 Steel Proclamation) and aluminum articles (the 2025 Aluminum Proclamation) into the United States (together, the 2025 Proclamations).
Trump’s steel and aluminum tariffs
On February 10 and 11, 2025, President Trump issued two proclamations pursuant to Section 232 of the Trade Expansion Act of 1962 (Section 232) announcing the imposition and/or reimposition of certain tariffs on imported steel articles (the 2025 Steel Proclamation) and aluminum articles (the 2025 Aluminum Proclamation) into the United States (together, the 2025 Proclamations).
Trump administration's tariffs targeting China, Canada and Mexico | JD Supra
On February 1, 2025, President Trump issued three Executive Orders (EOs) announcing tariffs on China (the China EO) Canada (the Canada EO), and Mexico (the Mexico EO), respectively, pursuant to the International Economic Emergency Powers Act of 1977 (IEEPA) (collectively, the EOs), marking the first time in its history IEEPA has been used to introduce tariffs.1 The tariffs have been introduced to address the synthetic opioid supply chain ( in the case of China), the flow of illicit drugs...
CFIUS Update: 2023 Report to Congress and new enforcement website | JD Supra
The Committee on Foreign Investment in the United States (CFIUS) continues to play an increasingly active role in reviewing and assessing inbound investment transactions for U.S. national security risks. In this alert, we provide an update on several recent developments, including key takeaways from CFIUS’s 2023 Annual Report to Congress and an overview of CFIUS enforcement actions from the Treasury Department’s new CFIUS enforcement website.
CFIUS Update: 2023 Report to Congress and New Enforcement Website
The Committee on Foreign Investment in the United States (CFIUS) continues to play an increasingly active role in reviewing and assessing inbound investment transactions for U.S. national security risks. In this alert, we provide an update on several recent developments, including key takeaways from CFIUS’s 2023 Annual Report to Congress and an overview of CFIUS enforcement actions from the Treasury Department’s new CFIUS enforcement website.
U.S. Department of the Treasury Publishes Outbound Investment Proposed Rule
On June 21, 2024, the U.S. Department of the Treasury (Treasury) issued a notice of proposed rulemaking (the Proposed Rule) to implement the Outbound Investment Security Program introduced pursuant to Executive Order 14105 (EO 14105). The Proposed Rule builds on the advance notice of proposed rulemaking (the ANPRM) published by Treasury last year.
US imposes new sanctions and export controls against Russia | JD Supra
ON THIS PAGE Additional blocking sanctions Expanded secondary sanctions risk for non-U.S. financial institutions Measures targeting IT and cloud-based services and related software New export controls on additional items destined for Russia Entity List additions Other export control measures Key takeaways On June 12, 2024, the U.S. Department of Treasury (Treasury), U.S. Department of State (State), and U.S. Department of Commerce (Commerce) announced another round of sanctions and export...
U.S. sanctions enforcement in the virtual currency space - USD 1 billion and counting... | JD Supra
Beginning in 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has increasingly focused its enforcement activity on entities operating in the virtual currency space, illustrating a trend that shows no signs of slowing. For much of the past decade, the virtual currency marketplace has operated under conditions more reminiscent of the “Wild West” than a clearly regulated financial market.
U.S. Imposes New Sanctions and Export Controls Targeting Russia | JD Supra
On February 23, 2024, marking the two-year anniversary of Russia’s invasion of Ukraine, the U.S. Departments of Commerce, State, and Treasury announced new U.S. sanctions and export controls targeting Russia. In addition, the U.S. government issued a business advisory regarding “Risks and Considerations for Doing Business in the Russian Federation and Russia-Occupied Territories of Ukraine”.
U.S. Government announces new West Bank-related sanctions and designations | JD Supra
On February 1, 2024, President Biden issued an Executive Order imposing certain sanctions on persons determined to be undermining peace, security, and stability in the West Bank. In response to current hostilities and reports of settler violence, forced displacement of people and villages, and property destruction in the West Bank, President Biden issued an “Executive Order on Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank” (the Executive Order).
Biden Administration Moves to Restrict Outbound Investment to China | JD Supra
On August 9, 2023, the Biden Administration issued a long-awaited Executive Order (the EO) that is intended to address the potential national security threats posed by outbound investment from the United States to certain countries of concern. The EO identifies each of the People’s Republic of China, the Special Administrative Region of Hong Kong, and the Special Administrative Region of Macau as a country of concern (Country of Concern).
On the one-year anniversary of Ukraine invasion, Biden Administration imposes additional sanctions and export controls targeting Russia | JD Supra
On February 24, 2023, the one-year anniversary of Russia’s invasion of Ukraine, the United States, in coordination with its G7 partners and other allies, announced a series of additional sanctions and export controls targeting Russia.
U.S. Russia sanctions and export controls update | JD Supra
December 5, 2022 Kuang Chiang, Jake Ely, Brendan Holman, Nick Ognibene, Maura Rezendes, Ken Rivlin, Ben Vallimarescu, Franchesca Verendia Allen & Overy LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: Since Russia’s invasion of Ukraine in February 2022, the United States has, in response, imposed unprecedented sanctions and export controls targeting Russia: President Biden has signed numerous new Executive Orders, the U.S....
U.S. bolsters national security reviews of in-bound foreign investment | JD Supra
President Biden recently issued “formal Presidential direction” on the risks that the United States will consider when evaluating in-bound foreign investment. Executive Order 14083 (EO 14083), issued on September 15, 2022, sets out an expanded range of national security factors that the Committee on Foreign Investment in the United States (CFIUS) must consider when evaluating in-bound investment into the United States.
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