On December 30, 2021, the Italian Government extended until the end of 2022 Italy’s emergency foreign direct investments (“FDI”) regime, which enables it to review also acquisitions of controlling stakes by European Economic Area (“EEA”) investors, as well as certain
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Global FDI Review Landscape Continues to Evolve
In 2022, boards of directors will continue to face a complex and expanding global foreign direct investment landscape that increasingly requires transactions to undergo intensive multijurisdictional FDI reviews and filing and approval processes, alongside merger control reviews and clearances. This…
Economic Sanctions: Developments and Considerations
U.S. sanctions policy in the first year of the Biden administration saw both change and continuity. As expected, the administration sought to cooperate with allies to impose multilateral (rather than unilateral) sanctions, focused on human rights abuses and opened the…
Australia and Canada Remain CFIUS Excepted Foreign States; United Kingdom and New Zealand Have Until February 2023 to Fulfill Criteria Necessary to Keep Designations
On January 5, 2022, the U.S. Department of the Treasury, as Chair of the Committee on Foreign Investment in the United States (“CFIUS”), determined that Australia and Canada have established and are effectively utilizing robust processes to analyze foreign investments…
Wide-Ranging New UK National Security Regime Comes Into Force
The National Security and Investment Act 2021, which was passed on 29 April 2021, comes into force today. The new regime, which subjects investments in many companies active in the UK to mandatory review on national security grounds, will be…
FinCEN Proposes Corporate Beneficial Ownership Reporting Rule
Last week, the Financial Crimes Enforcement Network (“FinCEN”) of the Department of the Treasury announced a Notice of Proposed Rulemaking (“NPRM”) to implement the beneficial ownership reporting requirements of the Corporate Transparency Act (“CTA”), part of the Anti-Money Laundering Act…
FinCEN Requests Input on Potential AML Requirements for Real Estate Transactions
On December 6, the Financial Crimes Enforcement Network (FinCEN) requested public input, through an advanced notice of proposed rulemaking (the ANPR), on the potential imposition of nationwide recordkeeping and reporting requirements on persons involved in certain residential and commercial real estate…
OFAC Imposes Sanctions on Belarusian Sovereign Debt, Announces New Designations
On December 2, 2021, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued a new directive (Directive 1) prohibiting with immediate effect U.S. persons from transacting or participating in the primary and secondary markets of new…
OFAC Ramps up Targeting of Ransomware-linked Actors and FinCEN Updates Ransomware Advisory
On November 8, 2021, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a virtual currency exchange, Chatex, and its infrastructure support providers on the list of Specially Designated Nationals and Blocked Persons (SDN List) for…
OFAC Issues Sanctions Guidance to Virtual Currency Industry
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued “Sanctions Compliance Guidance for the Virtual Currency Industry” (the “Guidance”). The Guidance follows recent guidance and advisory letters directed to the…