At least four SDNY lawsuits have been filed against Columbia University relating to the recent campus protests, including a class action complaint filed April 29, accusing the University of breaching its contractual obligation to provide a safe learning environment,
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Trilateral AUKUS Partnership Further Strengthened with Proposed New U.S. ITAR Exemptions and UK Open General Licenses
May 1, 2024, saw two major developments under the Australia, United Kingdom, and United States (“AUKUS”) Trilateral Security Partnership.
First, the U.S. Department of State (the “Department”) issued a notice of proposed rulemaking (“NPRM”) that would amend the International Traffic…
President Signs Expansive Sanctions Bill Into Law; Doubling of Limitations Period for IEEPA Violations Likely to Have Major Impact
On April 24, 2024, President Biden signed HR 815, “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes,” into law (the “National Security Supplemental” or the “NSS”). The National Security Supplemental appropriates…
Duty to Make Full Disclosures Under the UK’s Merger Control Regime
Under the UK’s merger control regime, there is no obligation to notify mergers to the Competition and Markets Authority (CMA). However, where merger parties wish to formally notify a merger, there is a duty for them to make full and…
United States and United Kingdom Take Coordinated Action Against Russian Federation Metals
On April 12, 2024, in a coordinated action the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) in the United States and the Foreign, Commonwealth, and Development Office, HM Treasury, and Department for Business and Trade (“DBT”) in…
CFIUS Proposes Important Changes to Foreign Investment Rules with Focus on Enforcement
On April 15, 2024, the U.S. Treasury Department (Treasury), as the Chair of the Committee on Foreign Investment in the United States (CFIUS or the Committee), published a notice of proposed rulemaking (NPRM) “to enhance certain CFIUS procedures and sharpen…
OFSI Issues Best Practices Guidance on Maritime Sector Financial Sanctions Compliance
On April 2, 2024, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a blog post addressing financial sanctions compliance in the maritime sector. Maritime businesses currently are a particular area of focus for UK sanctions regulators and law enforcement…
Avoid Submitting Misleading or Incorrect Information During a Merger Review Process or Face an Investigation Even After the Notification Is Withdrawn
In merger procedures, it is a fundamental requirement for parties to provide accurate and complete information to the European Commission as it forms the basis of the Commission’s assessment of mergers. Under the EU Merger Regulation (EUMR), the European Commission…
Export Controls and Sanctions Converge: New BIS Restrictions on SDNs
On March 21, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule under the U.S. Export Administration Regulations (“EAR”) that imposes new export controls on certain individuals and entities identified on the U.S. Department…
Federal Court Finds Corporate Transparency Act Unconstitutional: Navigating Implications for Reporting Companies
On March 1, 2024, the federal district court in the Northern District of Alabama declared in the case of National Small Business United v. Yellen that the Corporate Transparency Act (“CTA”) exceeds the Constitution’s limits on Congress’s power. The court…