Anti-Corruption

France Implements Sweeping Anti-Corruption ReformFrance Introduces Sweeping Anti-Corruption Reform

Anti-Dumping

Two Years On: Implementation of the New Methodology in Anti-Dumping CasesFirst Country Report on New EU Anti-dumping Rules ReleasedEU’s New Anti-dumping Methodology Enters Into Force

Arbitration

The New Supplemental Arrangement Concerning Enforcement of Arbitral Awards Between Mainland China and Hong KongIn Annulment Proceedings over ICC Award, Paris Court Rules on Nature of US, EU and UN Sanctions

Belarus

EU On Alert Towards Russian FDIOFAC Revokes Key General License Under Belarus Sanctions Program

Belgium

FDI Screening Mechanism Now Active in Belgium

Brexit

UK Competition Law After Brexit – Plus Ça Change…Brexit: No Change Until end-2020; Uncertainty ThereafterThe EU and UK Agree on Arrangements for Brexit Transition Period and Future Relationship Framework

CFIUS

U.S. Department of Agriculture Takes Next Step to Modernize AFIDA Filing Requirements and Strengthen EnforcementCleary Gottlieb Comments on CFIUS Known Investor Program and Process StreamliningDOJ Files First-Ever Complaint to Enforce CFIUS Divestment Order Against Suirui Group Co., Ltd.

China

Department of Defense Adds Major Technology, Automotive, and Biotechnology Firms to 1260H Chinese Military Companies ListPresident Trump Issues Order Requiring Chinese Company to Divest Interest in U.S. Video Processing Technology CompanyU.S. and UK, China Agree to Trade Deals Limiting Reciprocal Tariffs

China Trade

U.S. and UK, China Agree to Trade Deals Limiting Reciprocal TariffsThe European Commission targets Chinese battery electric vehicles with provisional duties to counteract subsidiesChina Passes “Anti-Foreign Sanctions Law”

COVID-19

Italy Further Broadens Its FDI RegimeChanges to the German Foreign Direct Investment Control Regime Take Shape Amid the COVID-19 CrisisCOVID-19: CFIUS Considerations for Distressed M&A and Lending Transactions

Cross-border M&A

UK National Security Regime: Enforcement Practice and Updated GuidanceU.S. Treasury Adopts Final Corporate Beneficial Ownership Reporting RuleGlobal Merger Control and Foreign Direct Investment Considerations Associated with Cross-Border Transactions

Cuba

Trump Administration Begins to Implement New Cuba Secondary Sanctions Regime Targeting Business With CubaDOJ Issues Final Rule Targeting Bulk Sensitive Personal and U.S. Government-Related Data Transactions Involving Countries of ConcernUS Tightens Controls on US-Origin Components in Goods Exported to Cuba

Disputes

Russia-Ukraine Disputes Taskforce: Risk of Criminal LiabilityRussia-Ukraine Disputes TaskforceFirst Country Report on New EU Anti-dumping Rules Released

Dual Use

BIS Tightens National Security Export ControlsEU Publishes Non-Binding Guidance on Internal Compliance Programmes for Dual-Use Trade Controls

Enforcement

Venezuela’s Oil Reform Efforts: New Opportunities, Unanswered Questions – U.S. Investor PerspectiveU.S. Government Removes Syria From List of State Sponsors of TerrorismU.S. Department of Agriculture Takes Next Step to Modernize AFIDA Filing Requirements and Strengthen Enforcement

Europe

Italy Introduces New Criminal Offenses and Corporate Liability for Breaches of EU SanctionsThe EU’s Latest Response to Trump II TariffsThe European Commission targets Chinese battery electric vehicles with provisional duties to counteract subsidies

Europe Trade

Italy Introduces New Criminal Offenses and Corporate Liability for Breaches of EU SanctionsThe EU’s Latest Response to Trump II TariffsCleary Gottlieb FDI Newsletter: November – December 2023

European Union

The Rise of the New EU FDI Screening RegulationEU FDI: State of the Union (2025)The Draft New EU FDI Regulation – The EU Institutional ‘Game Of Thrones’ Continues

Export Control

Venezuela’s Oil Reform Efforts: New Opportunities, Unanswered Questions – U.S. Investor PerspectiveBIS Further Restricts Exports of Artificial Intelligence and Advanced Chips to ChinaU.S. Government Signals Intent to Increase Enforcement of U.S. Export Controls

FDI

Cleary Gottlieb Comments on CFIUS Known Investor Program and Process StreamliningThe Restless Italian FDI Landscape: a Snapshot of the Latest DevelopmentsNew Guidance Issued and Changes Underway for U.S. Outbound Investment Regime as 2026 NDAA Defense Bill Introduces Outbound Investment, Sanctions, and Biotech Updates

FinTech

New Guidance Issued and Changes Underway for U.S. Outbound Investment Regime as 2026 NDAA Defense Bill Introduces Outbound Investment, Sanctions, and Biotech UpdatesPresident Biden Issues Order Requiring Chinese Owner to Divest Cryptocurrency Mining Facility Near U.S. Military BaseOFAC and FinCEN Announce Joint Enforcement Action Against U.S.-Based Digital Asset Exchange

Foreign Investment

Venezuela’s Oil Reform Efforts: New Opportunities, Unanswered Questions – U.S. Investor PerspectiveU.S. Government Removes Syria From List of State Sponsors of TerrorismU.S. Department of Agriculture Takes Next Step to Modernize AFIDA Filing Requirements and Strengthen Enforcement

Foreign Subsidies Regulation

MOFCOM Issues Final Determination on Trade and Investment Barrier Investigation into the EU’s Foreign Subsidies RegulationThe EU Foreign Subsidies Regulation: 2024 in Review and Predictions for 2025First Merger Commitments Adopted under the EU Foreign Subsidies Regulation

France

French Government Issues Guidelines on FDI RegulationGlobal FDI Review Landscape Continues to EvolveFrance Foreign Investment Control – New Rules Temporarily Applicable to non-EU/EEA Investments Enter Into Force Today

FTAs

European Commission’s Call for Proposals on Regulatory Cooperation under CETAAdoption of European Commission Mandate – Brexit Negotiations Can Now StartECJ Issues Opinion on Singapore FTA: Answers to Guide Brexit Trade Negotiators

Germany

Overall number of German FDI screenings slightly dropped in 2023, but review follows the trends of prior yearsThe evaluation of the German FDI Regime – Cornerstones of potential revisions revealedGerman FDI Reviews of Chinese Investments in 2022 Confirm the Current Trend – Strict Scrutiny and Political Dimension in Decision Making

Hong Kong

The New Supplemental Arrangement Concerning Enforcement of Arbitral Awards Between Mainland China and Hong KongState Department Releases Hong Kong Autonomy Act Persons Report, Starts the Clock for Foreign Financial Institutions ReportExecutive Order Eliminates Differential Treatment for Hong Kong

Illegality

OFAC Ramps up Targeting of Ransomware-linked Actors and FinCEN Updates Ransomware AdvisoryOFAC and FinCEN Issue Advisories on Cyber Ransom PaymentsRansomware and Sanctions Compliance: Considerations for Responses to Attacks

International Trade

OFAC Authorizes Commercial Negotiations With the Government of Venezuela and Certain Financial ServicesOFAC Issues Temporary Reprieve for Certain Russian-Origin Crude Oil ShipmentsU.S. Court of International Trade Orders Refunds of IEEPA Tariffs

Iran

DOJ Issues Final Rule Targeting Bulk Sensitive Personal and U.S. Government-Related Data Transactions Involving Countries of ConcernEconomic Sanctions: Developments and ConsiderationsIran Secondary Sanctions Expanded to Cover Construction, Mining, Manufacturing, and Textiles Sectors

Italy

The Restless Italian FDI Landscape: a Snapshot of the Latest DevelopmentsItaly Introduces New Criminal Offenses and Corporate Liability for Breaches of EU SanctionsItalian FDI, When the Government May Rewrite Corporate Governance

Japan

Opening Up European and Japanese Markets: What the EU-Japan Trade Deal Means for Businesses

Litigation

DOJ National Security Division Issues First Declination Under Merger-Related Safe Harbor ProvisionsEuropean Commission Publishes New Guidance on Scope of Sanctions ProhibitionsU.S. Supreme Court Holds FSIA Does Not Immunize Foreign Sovereigns From Criminal Prosecution

Mexico

United States and Mexico to Bolster Cooperation in Foreign Direct Investment Screening

North Korea

DOJ Issues Final Rule Targeting Bulk Sensitive Personal and U.S. Government-Related Data Transactions Involving Countries of ConcernCompromise U.S. Defense Bill Provides for New Secondary Sanctions Against Russia, Syria, and North KoreaSanctions Outlook: Congress to Consider Sanctions Provisions in FY2020 Defense Bill

Russia

OFAC Issues Temporary Reprieve for Certain Russian-Origin Crude Oil ShipmentsOFAC General Licenses Open Door for Lukoil Divestment and Other Limited Activities Following Rosneft and Lukoil SanctionsDOJ Issues Final Rule Targeting Bulk Sensitive Personal and U.S. Government-Related Data Transactions Involving Countries of Concern

Sanctions

OFAC Continues Venezuela Sanctions Relief with Authorizations for Aircraft Safety, Earthquake Relief, and Easing of General License Governing Law RequirementsTrump Administration Begins to Implement New Cuba Secondary Sanctions Regime Targeting Business With CubaOFAC Lifts Belarus Sovereign Debt Ban, Eases Sanctions on Belarusian Potash Sector

Syria

U.S. Government Removes Syria From List of State Sponsors of TerrorismU.S. Government Formally Terminates Economic Sanctions on SyriaU.S. Government Suspends Economic Sanctions on Syria; EU and UK Take Similar Actions

Trade Defense

European Commission Launches Public Online Consultation on Possible Methodology Changes in Trade Defense Investigations Regarding China

Trade Negotiations

U.S. Court of International Trade Orders Refunds of IEEPA TariffsOFAC Eases Venezuela Sanctions; Lifts Secondary Market Trading Ban on U.S. PersonsEU Trade Quarterly Summary

U.S.

OFAC Continues Venezuela Sanctions Relief with Authorizations for Aircraft Safety, Earthquake Relief, and Easing of General License Governing Law RequirementsVenezuela’s Oil Reform Efforts: New Opportunities, Unanswered Questions – U.S. Investor PerspectiveU.S. Government Removes Syria From List of State Sponsors of Terrorism

U.S. Trade

U.S. Court of International Trade Orders Refunds of IEEPA TariffsOFAC Issues General License 47 Authorizing Sale of U.S.-Origin Diluents to VenezuelaTrade Controls, Foreign Investment and National Security: New Regimes and Continuing Changes for 2026

Ukraine

Russian Countermeasures: The Governmental Commission Imposes Additional Conditions on Exits by Investors From Unfriendly Jurisdictions11th Package of EU Economic Sanctions Against RussiaUK Russian Sanctions Expanded Following G7 Summit

Uncategorized

Outbound Investment Screening Regime—EU May Follow In U.S. Footsteps

United Kingdom

U.S. Government Suspends Economic Sanctions on Syria; EU and UK Take Similar ActionsU.S. and UK, China Agree to Trade Deals Limiting Reciprocal TariffsSanctions on Russian Securities Infrastructure Create Additional Hurdles to Divesting from Russia

Venezuela

OFAC Continues Venezuela Sanctions Relief with Authorizations for Aircraft Safety, Earthquake Relief, and Easing of General License Governing Law RequirementsVenezuela’s Oil Reform Efforts: New Opportunities, Unanswered Questions – U.S. Investor PerspectiveOFAC Authorizes Commercial Negotiations With the Government of Venezuela and Certain Financial Services

WTO

EU Trade Quarterly SummaryEU Trade Quarterly SummaryEU Trade Quarterly Summary