Longer wait times to obtain regulatory approval to close transactions—often exceeding 90 days. More mitigation agreements. A less friendly Declarations process.Longer wait times to obtain regulatory approval to close transactions—often exceeding 90 days. More mitigation agreements. A less friendly Declarations process.
On July 31, the Committee on Foreign Investment in the United States (CFIUS or
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Congress Ramps Up Investigations of U.S. Venture Capital Firms Investing in Chinese Companies
Last week, a select committee of the U.S. House of Representatives sent letters to four venture capital (VC) firms requesting detailed information about their investments in Chinese companies developing technology involving artificial intelligence (AI), semiconductors, and quantum computing. The letters are a clear sign that Congress is ramping up its investigation of U.S. investments in…
China Places Export Controls on Raw Materials Used in Semiconductor Manufacturing
On July 3, 2023, the PRC Ministry of Commerce (“MOFCOM”) and the General Administration of Customs (“GAC”) announced the implementation of export controls on gallium and germanium items, effective August 1, 2023 (the “Announcement”).[1] The Announcement appears calculated to respond to semiconductor-related export controls imposed by the U.S. and its allies since 2022. In…
The EU Issues an Eleventh Package of Sanctions Against Russia
The European Union (EU) formally adopted an eleventh package of sanctions against Russia on June 23, 2023. This package focuses on preventing the circumvention of existing measures and includes a new anti-circumvention tool, new designations, additional import and export control bans and restrictions, new measures related to transport, tighter measures related to energy, clarification on…
CFIUS Publishes New FAQs Regarding Mandatory Filings and Disclosure Requirements for Investment Funds
The Committee on Foreign Investment in the United States recently issued two new frequently-asked-questions on its website. The new FAQs provide additional guidance on (1) timing for mandatory filings and (2) ownership disclosure requirements for investment funds. CFIUS does not have many FAQs—and they are not frequently updated—so the new FAQs are particularly noteworthy and…
U.S. Sanctions and Export Controls Against Russia and FinCEN Alert
On May 19, 2023, in coordination with the G7 summit in Japan, the U.S. announced new economic sanctions and export controls designed to further restrict the Russian Federation’s (Russia) ability to prosecute its invasion of Ukraine.On May 19, 2023, in coordination with the G7 summit in Japan, the U.S. announced new economic sanctions and export…
The EU Issues a Tenth Package of Sanctions Against Russia
In light of the recent wave of sanctions against Russia issued by the United States (see Winston & Strawn’s post here), the European Union (“EU”) issued a tenth package of Russia sanctions on February 25, 2023. In light of the recent wave of sanctions against Russia issued by the United States (see Winston & Strawn’s…
The United States and the United Kingdom Announce New Wave of Sanctions Against Russia
UNITED STATES
On Friday, February 24, 2023, the United States (U.S.) announced a new wave of sanctions and export controls restrictions against Russia aimed at (1) holding individuals and entities accountable for engaging in sanctions evasion, (2) imposing pressure on Russia’s key revenue-generating sectors including the energy, extractive, financial, defense, and technology sectors, and (3)…
Winston & Strawn’s International Trade Overview of U.S., E.U., and Japanese Sanctions: One Year After Russia’s Invasion of Ukraine
Since the start of Russia’s invasion of Ukraine on February 24, 2022, the United States (“U.S.”)—in partnership with the European Union (“EU”), the Group of Seven (“G7”),[1] and other Western countries— have designated 9,025 individuals, 2,636 entities, 119 vessels, and 22 aircraft.[2] In the U.S., the sanctions program against Russia has been codified…
China Adds Lockheed Martin and Raytheon Missiles & Defense to the Unreliable Entity List
China has come out of its zero-Covid slumber with a bang, utilizing its Unreliable Entity List to reiterate its ultimatum to companies regarding Taiwan. Companies doing business with Taiwan and mainland China in critical industries should take note.China has come out of its zero-Covid slumber with a bang, utilizing its Unreliable Entity List to reiterate…