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Potential policy changes could offer opportunities for CFIUS filers in low-risk transactions while introducing added challenges for transaction parties linked to sensitive countries.

By James Barker, Les Carnegie, Damara Chambers, Paul Rosen, Zachary Eddington, Ruchi Gill, and Catherine Hein

On April 24, 2025, Deputy Secretary of the Treasury Michael Faulkender spoke on the Committee on Foreign Investment in the United States (CFIUS) and the Outbound Investment Security Program at the American Conference Institute’s annual CFIUS…

The White House of the United States of America Building

The Trump administration presses forward with its tariff policy and introduces new election law and Treasury rules, while facing several new lawsuits challenging previous actions.

The Trump administration engaged in wide-ranging actions this week. It announced two new tariffs: one on automobile imports and another on countries that import oil from Venezuela. Additionally, it issued new rules for Treasury disbursements to agencies aimed at preventing fraud and waste, and imposed significant new election law requirements. Meanwhile, legal challenges to the…

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An executive order and related legislation centralizes Bitcoin and digital asset holdings across the federal government to optimize oversight and management of crypto as a US reserve asset.

By Jenny Cieplak, Zachary Fallon, Arthur S. Long, Yvette D. Valdez, Stephen P. Wink, Connor Jobes, and Deric Behar

On March 6, 2025, President Trump issued an executive order for the “Establishment of the Strategic Bitcoin Reserve and United States Digital Asset Stockpile” (the Order). As…

The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities.

By Eric Volkman and Lucas Baker

On February 20, 2025, the US Department of State designated eight drug cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). This action implements Executive Order 14157 and is also in accordance with the US Attorney General’s February 5, 2025, Memo (“Total Elimination of Cartels and…

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The policy memo aims to preserve an open investment environment as well as restrict investment in strategic sectors.

By James H. Barker, Les P. Carnegie, Damara L. Chambers, Zachary N. Eddington, Ruchi G. Gill, and Catherine Hein

Late on Friday, February 21, 2025, the White House released its “America First Investment Policy” memorandum.

The presidential action seeks to enhance US national and economic security by directing department and agency heads to preserve an open investment…

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Navigating Trump administration executive orders impacting digital assets and cryptocurrency.

By Yvette Valdez, Stephen Wink, Zachary Fallon, Benjamin Naftalis, and Douglas Yatter

See EO: Strengthening American Leadership in Digital Financial Technology

Date Issued: January 23, 2025

Agency Impacted: Treasury, DOJ, SEC, CFTC, DHS

Summary: This EO seeks to enhance US leadership in digital assets and financial technology while protecting economic liberty. It promotes responsible growth and use of digital assets, supports the development of dollar-backed stablecoins…

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Navigating Trump administration executive orders impacting CFIUS, national security, and trade.

By James Barker, Les Carnegie, Damara Chambers, Philip Perry, Ruchi Gill, Catherine Hein, and Kathryn Worthington

See EO: America First Trade Policy

Date Issued: January 20, 2025

Agency Impacted: State, Treasury, Defense, Commerce, Homeland Security, OMB

Summary: This EO tasks the Secretary of State and the Secretary of Commerce, in cooperation with the heads of other agencies with export control authorities, to…

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Navigating Trump administration executive orders impacting environment and energy initiatives.

By Janice Schneider, Jean-Philippe Brisson, Nikki Buffa, and Betty M. Huber

See EO: Temporary Withdrawal of All Areas on the Outer Continental Shelf from Offshore Wind Leasing and Review of the Federal Government’s Leasing and Permitting Practices for Wind Projects

Date Issued: January 20, 2025

Agency Impacted: Interior, Agriculture, Energy, EPA, NOAA, Treasury, Justice

Summary: This presidential memorandum temporarily halts wind energy leasing across all areas of…