On December 18, 2025, President Trump signed the 2026 National Defense Authorization Act (“NDAA”), a sweeping defense spending bill that brings a number of changes to the U.S. outbound investment security program, U.S. economic sanctions, and biotechnology restrictions relating to federal procurement. First, the NDAA includes the Comprehensive Outbound Investment National Security (“COINS”) Act, which provides
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BIS Further Restricts Exports of Artificial Intelligence and Advanced Chips to China
For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.
In the final weeks of the Biden Administration and early days of the second Trump Administration, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued…
U.S. Government Signals Intent to Increase Enforcement of U.S. Export Controls
For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.
Earlier this month, the U.S. Department of Commerce (Commerce), Bureau of Industry and Security (BIS) held its annual Update Conference on Export Controls and Policy (the Conference). During…
President Trump Issues “America First Investment Policy”: Confirms U.S. Openness to Foreign Investment from Allies and Partners, Calls for Enhanced Restrictions on Investments from and into China
For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.
On February 21, 2025, President Trump issued a memorandum to various U.S. government agencies setting forth an “America First Investment Policy” (the “Memorandum”). While the Memorandum is a…
Global FDI Newsletter: October – December 2024
Global FDI enforcement continued to evolve rapidly in Q4 2024, as shown by the range of developments summarized in this newsletter.…
The EU Commission Urges Member States to Review Outbound Investments
On January 15, 2025, the European Commission (the “EC”) published a recommendation (the “Recommendation”)[1] addressed to all EU Member States urging them to review “outbound investments” in certain critical technologies sectors, notably semiconductors, artificial intelligence (“AI”), and quantum technologies.…
Commerce Issues Final ICTS Rule; Takes Steps to Implement the Program
On December 5, 2024, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) implementing the procedures BIS will follow when reviewing information and communications technology (“ICTS”) transactions that may pose a risk to U.S. national security pursuant to Executive Order (E.O.) 13873.[1] …
You’re Invited: U.S. Outbound Investment Security Program Webinar on January 7, 2025
The Treasury Department has released its “Final Rule” which will impose on U.S. persons notification requirements and restrictions for transactions involving entities engaged in activities relating to semiconductors and microelectronics, quantum information technologies, and artificial intelligence systems in “countries of concern.” The rule will go into effect on January 2, 2025.…
You’re Invited: U.S. Outbound Investment Security Program Webinar on December 16, 2024
The Treasury Department has released its “Final Rule” which will impose on U.S. persons notification requirements and restrictions for transactions involving entities engaged in activities relating to semiconductors and microelectronics, quantum information technologies, and artificial intelligence systems in “countries of concern.” The rule will go into effect on January 2, 2025.…
Long-Awaited U.S. Outbound Investment Regime Published, Will Become Effective January 2, 2025
On October 28, 2024, the U.S. Department of the Treasury (“Treasury”) issued a long-awaited Final Rule (the “Final Rule”) implementing the U.S. Outbound Investment Security Program (the “Program”).[1] Under the Program, effective January 2, 2025, U.S. persons will be prohibited from engaging in, or required to notify Treasury regarding, a broad range of transactions…