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Jan 8, 2025 | 
mondaq.com | Adam Hickey |Aaron Futerman |Mickey Leibner
On December 20, 2024, the US Department of Justice (DOJ) issueda long-awaited notice of proposed rulemaking (NPRM) to revise regulationsunder FARA, three years after an Advance Notice of ProposedRulemaking sought input on 19 questions about them. Below wediscuss the most significant proposed changes to the rules. Thecomment period will run for 60 days from publication of the NPRM inthe Federal Register.
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Dec 18, 2024 | 
jdsupra.com | Mickey Leibner
After yet another banner year for the Foreign Agents Registration Act (FARA)—including high-profile prosecutions, an all-time high in registrations, a record number of inspections, and a key DC Circuit decision—US Department of Justice (DOJ) officials made a number of notable announcements at a recent conference for practitioners (the “FARA Conference”), demonstrating their continued focus on this enforcement area in 2025.
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Nov 13, 2024 | 
jdsupra.com | Timothy J. Keeler |Mickey Leibner
[co-author: Emily King]On November 1, 2024, the US Department of the Treasury, in its capacity as chair of the Committee on Foreign Investment in the United States (CFIUS), issued a final rule (“Final Rule”) expanding the list of military and government sites designated as sensitive.
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Nov 12, 2024 | 
mondaq.com | Timothy J. Keeler |Mickey Leibner |Emily King
On November 1, 2024, the US Department of the Treasury, in its
capacity as chair of the Committee on Foreign Investment in the
United States (CFIUS), issued a final rule (“Final
Rule”) expanding the list of military and government sites
designated as sensitive. Based on CFIUS's authority to review
“covered real estate transactions” involving foreign
persons in proximity to these sites, the expanded list
substantially increases the scope of real estate transactions
subject to CFIUS jurisdiction.
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Nov 7, 2024 | 
mondaq.com | Timothy J. Keeler |Mickey Leibner |Nicholas Jackson |Rajesh De
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Sep 30, 2024 | 
jdsupra.com | Arsen Kourinian |Mickey Leibner |Howard W. Waltzman
On September 19, 2024, California Governor Gavin Newsom signed into law the California AI Transparency Act, which will require providers of generative artificial intelligence (AI) systems to: (a) make available an AI detection tool; (b) offer AI users the option to include a manifest disclosure that content is AI generated; (c) include a latent disclosure in AI-generated content; and (d) enter into a contract with licensees requiring them to maintain the AI system’s capability to include such...
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Sep 25, 2024 | 
mondaq.com | Howard W. Waltzman |Mickey Leibner
On September 19, 2024, California Governor Gavin Newsom signed into law the California AI Transparency Act, which will require providers of generative artificial intelligence (AI) systems to: (a) make available an AI detection tool; (b) offer AI users the option to include a manifest disclosure that content is AI generated; (c) include a latent disclosure in AI-generated content; and (d) enter into a contract with licensees requiring them to maintain the AI system's capability to include such...
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Sep 23, 2024 | 
lexology.com | Arsen Kourinian |Howard W. Waltzman |Mickey Leibner
On September 19, 2024, California Governor Gavin Newsom signed into law the California AI Transparency Act, which will require providers of generative artificial intelligence (AI) systems to: (a) make available an AI detection tool; (b) offer AI users the option to include a manifest disclosure that content is AI generated; (c) include a latent disclosure in AI-generated content; and (d) enter into a contract with licensees requiring them to maintain the AI system’s capability to include such...
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Sep 12, 2024 | 
mondaq.com | Adam Hickey |Timothy J. Keeler |Kelly Kramer |Mickey Leibner
As predicted earlier this year in our January update, the US Department of Justice
(DOJ) has continued to ramp up enforcement of the Foreign Agents
Registration Act (FARA) and related political laws through criminal
prosecution. This Legal Update provides a brief summary of recent
criminal cases, and highlights several issues to watch in the
coming months.
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Aug 19, 2024 | 
lexology.com | Timothy J. Keeler |Adam Hickey |Stephen Lilley |Shelby Colson |Mickey Leibner
On August 14, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) announced a $60 million penalty, “the largest penalty CFIUS has ever issued,” following its finding of material violations relating to a National Security Agreement (NSA).
