Nathan Mitchell

1 month ago | lexology.com | L. Atkinson |John Carlin |Roberto González |David Kessler |Samuel Kleiner |Nathan Mitchell | +2 more

On February 21, 2025, President Trump issued a national security presidential memorandum (“NSPM”) outlining the America First Investment Policy.[1] The NSPM predominantly focuses on the United States’ two primary national-security regulatory programs for investors: (i) the recently implemented U.S. Outbound Investment Security Program (“OISP”)[2] and (ii) the Committee on Foreign Investment in the United States (“CFIUS”).

Oct 15, 2024 | lexology.com | L. Atkinson |Jessica Carey |John Carlin |Roberto González |Brad S. Karp |Loretta Lynch | +7 more

On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance to financial institutions on “best practices” for compliance with the Export Administration Regulations (“EAR”), including General Prohibition 10.[1] The Guidance appears to mark the first time that BIS has formally indicated that U.S. and non-U.S. financial institutions could be the subject of enforcement actions by BIS for violating the export control regulations directly.

Oct 2, 2024 | lexology.com | L. Atkinson |Jessica Carey |John Carlin |Roberto González |Brad S. Karp |Loretta Lynch | +7 more

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently issued new regulations that will have significant impacts on the compliance obligations of persons subject to U.S. jurisdiction, and particularly financial institutions. First, OFAC issued a Final Rule that describes the types of non-public “tailored actions” it can take.

Aug 14, 2024 | today.westlaw.com | Jessica Carey |John Carlin |L. Atkinson |Nathan Mitchell

(September 05, 2024) - Jessica S. Carey, John P. Carlin, L. Rush Atkinson and Nathan Mitchell of Paul, Weiss, Rifkind, Wharton & Garrison LLP explore the findings of the Committee on Foreign Investment in the United States' recently released annual review for 2023.

Jul 11, 2024 | lexology.com | L. Atkinson |Jessica Carey |John Carlin |Harris B Freidus |Salvatore Gogliormella |Samuel Kleiner | +3 more

On July 8, 2024, the U.S. Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPRM”) that would expand the jurisdiction of the Committee on Foreign Investment in the United States (“CFIUS”) with respect to certain transactions by foreign persons involving real estate near certain U.S. military installations.[1] A Treasury official stated that update “vastly expands the reach of CFIUS' real estate jurisdiction.”[2] Background In 2018, Congress passed the Foreign...