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On October 14, 2025, the European Commission (“Commission”) published its fifth annual report on the screening of foreign direct investments (“FDI”) into the Union (the “Report”). Notable findings:Continue Reading EU FDI: State of the Union (2025)

I. Introduction

    On June 11, 2025, the Council of the European Union (the “Council”) put forward changes[1] to the draft new EU FDI Regulation proposed by the European Commission (the “EC”) in January 2024, following changes put forward by the European Parliament (the “Parliament”) in May 2025.  These proposals will now kick-off trilogue negotiations among the EU institutions with the aim of reaching a political agreement on the final text of the revised regulation in due course.[2]Continue Reading The Draft New EU FDI Regulation – The EU Institutional ‘Game Of Thrones’ Continues

    For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.

    On May 23, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”), titled “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons.”  Effective immediately, GL 25 suspends nearly all OFAC sanctions on Syria, in line with President Trump’s prior announcement that he intended to lift sanctions on Syria following the ouster of former Syrian President Bashar al-Assad and the establishment of a new government under Syrian President Ahmed al-Sharaa.Continue Reading U.S. Government Suspends Economic Sanctions on Syria; EU and UK Take Similar Actions

    On February 1, 2025, U.S. President Donald Trump imposed a 25% additional tariff on imports of Canadian- and Mexican-origin goods (since suspended for 30 days) and a 10% additional tariff on imports of Chinese-origin goods.  On February 10, President Trump announced a 25% tariff on steel and aluminum imports,[1] and is preparing “a comprehensive plan” to tackle “non-reciprocal trading arrangements”.[2]  The EU is a key target of the new measures, with the EU’s 10% tariff on imported cars and ban on U.S. shellfish imports identified as unfair trade barriers.  As with Canada and Mexico, any EU tariffs may be driven by other strategic objectives, such as NATO expenditure and a takeover of Greenland.Continue Reading The EU’s Possible Response to Trump II Tariffs

    On January 9, 2025, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) released its decision in a trade and investment barrier investigation into the European Union’s Foreign Subsidies Regulation (“FSR”).Continue Reading MOFCOM Issues Final Determination on Trade and Investment Barrier Investigation into the EU’s Foreign Subsidies Regulation

    In 2024, the FSR’s first year in operation saw a large number of filings but limited enforcement, with only a handful of Phase 2 reviews, one conditional merger clearance and two ex officio cases. With the FSR now up and running, in 2025, we expect the EC’s focus to be on demonstrating the FSR’s value and delivering practical results by stepping up enforcement, building a corpus of reasoned decisions, and – it is hoped – developing a more streamlined process for non-issue cases.Continue Reading The EU Foreign Subsidies Regulation: 2024 in Review and Predictions for 2025

    On January 15, 2025, the European Commission (the “EC”) published a recommendation (the “Recommendation”)[1] addressed to all EU Member States urging them to review “outbound investments” in certain critical technologies sectors, notably semiconductors, artificial intelligence (“AI”), and quantum technologies.Continue Reading The EU Commission Urges Member States to Review Outbound Investments

    The Russian financial services sector remains a key target of U.S., UK, and EU sanctions.  As discussed below, a number of recent such sanctions against Russia and countermeasures by the Russian government  have further complicated efforts for investors seeking to divest listed securities from Russia.Continue Reading Sanctions on Russian Securities Infrastructure Create Additional Hurdles to Divesting from Russia

    On October 17, 2024, the European Commission (“Commission“) published its forth annual report on the screening of foreign direct investments (“FDI“) into the Union (the “Report“), following previous editions published in October 2023, September 2022 and November 2021. Notable findings include the follow:Continue Reading EU FDI: State Of The Union (2024)

    On October 4, 2024, the European Commission proposal to impose definitive countervailing duties of up to 35.3% on imports of battery electric vehicles (BEVs) from China was adopted by the Council.  The duties are imposed on top of the 10% EU import duty for cars. Continue Reading Definitive Duties Adopted by the EU on Chinese Battery Electric Vehicles to Counteract Subsidies to Apply by October 30