- The Order directs federal agencies to strengthen cybersecurity across government systems and critical infrastructure, including through an AI cybersecurity clearinghouse and expanded access to AI-enabled defensive tools for state and local authorities.
- Federal agencies will design a voluntary framework by August 1, 2026, for
FinCEN Proposes Regulations to Implement Whistleblower Program: 4 Key Takeaways
The program provides new financial incentives for whistleblowers to report information about potential violations of money laundering and sanctions laws.
By Joseph M. Bargnesi, Les P. Carnegie, Andrew P. Galdes, Eric S. Volkman, Douglas K. Yatter, Jewel Drigo, Allayne Thomas, and Nicole Kerrigan
On March 30, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) to establish a whistleblower program designed to encourage
Deputy Treasury Secretary Provides Key Insights Into CFIUS and Outbound Policy Direction
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
Week 10 in Review: More Tariffs, Treasury Rules, and Restrictions on Federal Workforce
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
President Trump Issues Executive Order Establishing a Strategic Bitcoin Reserve
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
Trump Administration Targets Cartels With First Wave of Terrorism Designations
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
White House Issues America First Investment Policy
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
Executive Order: “Strengthening American Leadership in Digital Financial Technology”
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
Executive Order: “America First Trade Policy”
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
Executive Order: “Temporary Withdrawal of All Areas on the Outer Continental Shelf from Offshore Wind Leasing”
Navigating Trump administration executive orders impacting environment and energy initiatives.
By Janice Schneider, Jean-Philippe Brisson, Nikki Buffa, and Betty M. Huber
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