Emphasis on protecting US business, economic and national security interests In brief During a May 12 speech and in a newly issued Criminal Division White-Collar Enforcement Plan (the “Plan”), the Head of the US Department of Justice (DOJ)’s Criminal Division, Matthew R. Galeotti, set out the Department’s priorities for corporate criminal enforcement under the new Administration and issued a number of updated policy documents. These changes affect the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure…
On March 24, 2025, the White House issued Executive Order 14245 (“EO 14245”) to implement potential tariffs for countries importing Venezuelan oil as well as a Fact Sheet that summarizes EO 14245 at a high level. On the same date, the US Treasury Department’s Office of Foreign Assets Control issued General License (“GL”) No. 41B extending the wind down period of certain transactions related to Chevron Corporation joint ventures (“JVs”) in Venezuela. EO 14245 This…
On January 16, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) related to advanced computing integrated circuits (“ICs”) designed to protect US national security and assist foundries and Outsourced Semiconductor Assembly and Test (“OSAT”) companies in complying with provisions of the US Export Administrations Regulations (“EAR”). The IFR builds on previous waves of semiconductor export controls published in October 2022, October 2023, April 2024, and December…
On December 13, 2024, the US Treasury Department (“Treasury”) issued 35 new questions and answers (“FAQs”) providing guidance on the November 17, 2024 final rule outlining the US government’s Outbound Investment Security Program (“Outbound Investment Rules”). These Outbound Investment Rules, which become effective January 2, 2025, implement a targeted outbound investment compliance regime called for by Executive Order (EO) 14105 issued by President Biden on August 9, 2023. The full list of published FAQs can…