On October 7, 2026, the U.S. Department of the Treasury announced that, in July 2026, it issued its first civil penalty under the Outbound Investment Security Program (OISP). Treasury penalized a U.S. company $200,000 for failing to submit a required notification of an investment by the company’s controlled foreign entity, a Chinese fund. On April
Lee Williams
CFIUS annual report for 2025: Key takeaways
On August 7, 2026, the Committee on Foreign Investment in the United States (“CFIUS”) released its annual report to Congress for calendar year 2025. The report covers 347 covered transactions, consisting of 207 written notices and 140 declarations, that were filed for CFIUS review last year.
CFIUS is an interagency committee authorized to review certain transactions involving foreign investment in the United States and the effect of those transactions on U.S. national security. The Committee is required to provide an annual report to Congress containing specific, cumulative, and trend information related to transaction filing.
Continue Reading CFIUS annual report for 2025: Key takeawaysExecutive Order 14420 Restricts Foreign Equipment in the U.S. Bulk-Power System
Overview
On August 26, 2026, President Trump signed Executive Order 14420 (EO), declaring a national emergency to secure the U.S. bulk-power system and restrict procurement and installation of a broad array of foreign-produced equipment used in the U.S. electric power industry that is linked to “Covered Foreign Entities,” a list of entities that notably includes China. Implementing regulations are expected within 120 – 180 days.
Continue Reading Executive Order 14420 Restricts Foreign Equipment in the U.S. Bulk-Power SystemDoD proposes expanding FOCI requirements to unclassified contracts
- Covered contractors determined to be under FOCI
National security meets the farm bill: Key provisions in the Farm, Food, and National Security Act of 2026
On April 30, 2026, the U.S. House of Representatives passed the Farm, Food, and National Security Act of 2026 (H.R. 7567). The legislation extends agricultural programs through 2031 and contains significant national security elements, beyond the headline coverage of food stamp cuts and pesticide liability changes. Notably, the bill does not impose a sweeping ban…
Tariff refunds: What U.S. importers should know as the Supreme Court weighs the tariffs’ legality
During the Supreme Court’s oral argument in Learning Resources v. Trump last month, Justice Barrett asked counsel for the private plaintiffs about the tariff refund process if his clients prevail. After some back and forth, she summarized: “So a mess?”
Although the Court has not yet announced when an opinion may be released, entries subject…