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Articles by John Beahn
U.S. Treasury Department Proposes to Expand Outbound Investment Rule
Home - Perspectives - U.S. Treasury Department Proposes to Expand O... On October 22, 2026, the U.S. Department of the Treasury (“Treasury Department”) issued a Notice of Proposed Rulemaking (“NPRM”) that proposes to solidify and significantly expand the U.S. Outbound Investment Rule (“OIR”) program in accordance with the requirements of the Comprehensive Outbound Investment National Security (“COINS”) Act of 2025.
Trump Administration Proposes CFIUS "Known Investor" Program
ML Milbank LLP More Milbank LLP is a leading international law firm that provides innovative legal services from 11 offices around the world. Founded in New York over 150 years ago, Milbank helps the world’s leading commercial, financial and industrial enterprises, as well as institutions, individuals and governments, achieve their strategic objectives.
OFAC Issues General License Easing Sanctions On Venezuelan Oil Sector
Milbank LLP are most popular: within International Law, Family and Matrimonial and Tax topic(s) with readers working within the Accounting & Consultancy and Aerospace & Defence industries On January 29, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury ("OFAC") issued General License No. 46 (Authorizing Certain Activities Involving Venezuelan-Origin Oil) ("General License 46"), authorizing certain transactions that would otherwise be prohibited under the...
Landmark FinCEN Orders Prohibit Fund Transfers Involving Three Mexican Financial Institutions Based On Illicit Opioid Trafficking Concerns
On June 25, 2025, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury ("FinCEN") issued three orders (the "FinCEN Orders") targeting, and prohibiting certain U.S. persons from engaging in any transfer of funds involving, three Mexican financial institutions: CIBanco S.A., Institución de Banca Multiple ("CIBanco"), Intercam Banco S.A., Institución de Banca Multiple ("Intercam") and Vector Casa de Bolsa, S.A. de C.V. ("Vector").
Trump Administration Proposes Significant Changes To CFIUS And The Outbound Investment Review Processes
On February 21, 2025, President Donald J. Trump released a National Security Presidential Memorandum ("Memorandum") proposing broad revisions to the inbound and outbound investment screening review processes maintained and administered by the U.S. Department of the Treasury ("Treasury"), including the Committee on Foreign Investment in the United States ("CFIUS"). The Memorandum simultaneously seeks to relax and heighten regulations and scrutiny of a broad array of investments and transactions.
Trump Administration Proposes Significant Changes to CFIUS and the Outbound Investment Review Processes
On February 21, 2025, President Donald J. Trump released a National Security Presidential Memorandum ("Memorandum") proposing broad revisions to the inbound and outbound investment screening review processes maintained and administered by the U.S. Department of the Treasury ("Treasury"), including the Committee on Foreign Investment in the United States ("CFIUS"). The Memorandum simultaneously seeks to relax and heighten regulations and scrutiny of a broad array of investments and transactions.
President Trump Signs Executive Order Pausing Enforcement Of The U.S. Foreign Corrupt Practices Act
On February 10, 2025, President Donald J. Trump issued an executive order (the "Executive Order") directing a pause in enforcement of the U.S. Foreign Corrupt Practices Act of 1977, as amended (the "FCPA"), a U.S. law that prohibits bribery of foreign government officials in connection with international business transactions.
BIS Issues New Rule Expanding Controls On Export, Reexport And Transfer Of Advanced Computing Chips And Artificial Intelligence Model Weights
On January 13, 2025, the Bureau of Industry and Security ("BIS") of the U.S. Department of Commerce issued an interim final rule on a Framework for Artificial Intelligence Diffusion (the "AI Diffusion Rule") aimed at expanding the existing U.S. export control framework to address the growing threat to U.S. national security and foreign policy that is presented by diffusion of advanced computing integrated circuits (or chips) and advanced artificial intelligence ("AI") models.
CFIUS Proposes To Expand Its Enforcement And Procedural Authorities
On April 11, 2024, the US Treasury Department proposed to expand the enforcement and transaction review authorities of the Committee on Foreign Investment in the United States ("CFIUS" or the "Committee").
U.S. Executive Order Proposes Restrictions On Certain Cross-Border Data Transactions
On February 28, 2024, the Biden Administration released an Executive Order("EO") that will establish new regulations prohibiting, or otherwise restricting, certain categories of commercial data transactions that pose an unacceptable risk to U.S. national security.
Biden Administration Releases Executive Order Proposing Outbound Investment Regime
On August 9, 2023, the Biden Administration released a long-awaited Executive Order ("EO") establishing an outbound investment review program (the "Program") for investments by U.S. companies and investors in China-based entities that are engaged in certain activities involving a defined set of sensitive technologies and products.
Beyond CFIUS: The Growing Use Of US Export Controls To Control Foreign Direct Investment - International Law - United States
To print this article, all you need is to be registered or login on Mondaq.com. Export controls have been used for decades to protect U.S. technology with military applications. In recent years, however, these controls have expanded to such an extent that some investments or acquisitions in certain U.S. companies may now be precluded.
Corporate Transparency Act, CFIUS, And Other Real Estate Disclosure Requirements - Real Estate and Construction - United States
United States: Corporate Transparency Act, CFIUS, And Other Real Estate Disclosure Requirements 24 May 2021 by Kris Ferranti and John M. Beahn Shearman & Sterling LLP Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Proposed Extension Of CFIUS Jurisdiction To Foreign Gifts To US Colleges And Universities
To print this article, all you need is to be registered or login on Mondaq.com. The Senate Foreign Relations Committee this week approved legislation that would authorize and require the Committee on Foreign Investment in the United States to review the national security implications of foreign gifts to U.S. public and private colleges and universities, as well as foreign contracts with such institutions.
CFIUS and Beyond – Navigating the Complicated Universe of Regulatory and Other Constraints Related to US National Security | JD Supra
The reach and authority of the U.S. government over what it considers to be national security concerns is broad, increasing and often not subject to judicial appeal. In response to mounting threats to the personal, economic and national security of Americans – real or not – extensive regulatory frameworks have been implemented, expanded or co-opted to protect U.S. national security.
CFIUS And Beyond - Navigating The Complicated Universe Of Regulatory And Other Constraints Related To Us National Security - Government, Public Sector - United States
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CFIUS Proposes Changes To Mandatory Filing Requirements
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New Controls Target Tech Exports To China, Russia And Venezuela
To print this article, all you need is to be registered or login on Mondaq.com. On April 28, 2020, the Trump Administration significantly expanded the reach of U.S. export controls over certain items and certain countries, changes that will have a particularly limiting impact on particular exports to China, Russia and Venezuela.
Client Alert: CFIUS Proposes Changes to Mandatory Filing Requirements | JD Supra
The U.S. Treasury Department this week published draft regulations changing the requirements for mandatory CFIUS filings for transactions in which a foreign person acquires or invests in a U.S. critical technology company. Under the proposed rule, the trigger for the mandatory CFIUS filing requirement would depend on whether U.S. export licenses are required for shipments of the U.S. target’s products or technology to the foreign investor’s country of origin.
Foreign Investment Review in Europe: Key Considerations for Investors and Latest Developments Prompted by COVID-19 | JD Supra
Global foreign direct investment (FDI) amounted to 1,426 billion USD in 2019. In recent years, a number of countries around the world have implemented measures to strengthen their FDI review mechanisms. Undoubtedly, this worldwide trend is having an impact on international mergers and acquisitions transactions as illustrated by a number of cases highlighted in the media.
COVID-19 Insights Series: Considerations When Buying Distressed Energy Assets (Oil & Gas; Power & Renewables) (Video)
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New Controls Target Tech Exports to China, Russia and Venezuela | JD Supra
On April 28, 2020, the Trump Administration significantly expanded the reach of U.S. export controls over certain items and certain countries, changes that will have a particularly limiting impact on particular exports to China, Russia and Venezuela.
The Defense Production Act—What Us Businesses Need To Know - Coronavirus (Covid-19) - United States
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The Defense Production Act—What US Businesses Need to Know | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
CFIUS Proposes Filing Fees For Transaction Reviews
To print this article, all you need is to be registered or login on Mondaq.com. The U.S. Department of the Treasury late yesterday released a draft set of regulations that would establish, for the first time, filing fees for most transactions submitted to the Committee on Foreign Investment in the United States (CFIUS).
CFIUS Proposes Filing Fees for Transaction Reviews | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Final CFIUS Regulations Implement Significant Changes by Broadening Jurisdiction and Updating Scope of Reviews
The U.S. Department of the Treasury issued final regulations late yesterday that significantly expand the authorities of the Committee on Foreign Investment in the United States (CFIUS) to conduct national security reviews of foreign investments in U.S. businesses. Issuance of the final regulations culminates a multi-year legislative and regulatory process to modernize the CFIUS process.
Final CFIUS Regulations Implement Significant Changes by Broadening Jurisdiction and Updating Scope of Reviews | JD Supra
The U.S. Department of the Treasury issued final regulations late yesterday that significantly expand the authorities of the Committee on Foreign Investment in the United States (CFIUS) to conduct national security reviews of foreign investments in U.S. businesses. Issuance of the final regulations culminates a multi-year legislative and regulatory process to modernize the CFIUS process.
US Government Actions Greatly Increase Oversight Of US Supply Chains
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US Government Actions Greatly Increase Oversight of US Supply Chains | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Legislation Proposes Sweeping New Foreign Investment Review Authorities
On November 8, 2017, a bipartisan group of legislators led by U.S. Sen. John Cornyn, R-Texas, and U.S. Rep. Robert Pittenger, R-N.C., alongside co-sponsors including U.S. Sen.
FCC Proposes to Roll Back Net Neutrality Regulations
The Federal Communications Commission (FCC) recently commenced a highly contentious proceeding to begin the rollback of various aspects of its network neutrality regulations, which it adopted on a party-line vote under the Obama administration in March 2015.
FCC Proposes to Roll Back Net Neutrality Regulations
The Federal Communications Commission (FCC) recently commenced a highly contentious proceeding to begin the rollback of various aspects of its network neutrality regulations, which it adopted on a party-line vote under the Obama administration in March 2015.
"National Security Investigation of Imported Steel Could Be Prelude to Similar Actions Against Other Imports"
On April 20, 2017, President Donald Trump directed the Department of Commerce (Commerce) to conduct an expedited investigation of the harmful impact of steel imports on U.S. national security. The investigation, which will be conducted under Section 232 of the Trade Expansion Act of 1962, may result in duties, quotas or other measures to restrict harmful imports into the United States.
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