Richard Elliott

Mar 12, 2024 | lexology.com | L. Atkinson |Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto González | +10 more

On March 6, the Department of Commerce’s Bureau of Industry and Security (“BIS”), the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the Department of Justice (“DOJ”) issued their most recent ”tri-seal” compliance note (the “Compliance Note” or “the Note”).[1]The Compliance Note highlights that U.S. sanctions and export controls apply to non-U.S. persons, both companies and individuals, in a variety of circumstances.

Mar 7, 2024 | lexology.com | L. Atkinson |Jessica Carey |John Carlin |Roberto González |Peter Carey |Richard Elliott | +4 more

In mid-February, the White House Office of Science and Technology Policy (“OSTP”)[1] released a revised list of critical and emerging technologies (“CETs”) that it calls “potentially significant to U.S. national security” (the “CET List”).[2] The CET List does not cause immediate changes to the regulatory regimes administered by U.S. national security agencies, but it does provide notice concerning the types of emerging technologies that are likely to draw attention from these agencies.

Feb 21, 2024 | lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto González | +4 more

On February 13, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a proposed rule aimed at “keep[ing] criminals and foreign adversaries from exploiting the U.S. financial system and assets through investment advisers” (the “Proposed Rule”).[1] The Proposed Rule would require SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) (together, “Covered Investment Advisers”) to establish anti-money laundering/countering the...