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On August 9, 2023, President Biden issued his much anticipated executive order on outbound U.S. investment in China, Hong Kong, and Macau (dubbed “reverse CFIUS”). The Treasury Department simultaneously released an advance notice of proposed rulemaking (ANPRM) related to the order. Public comments on the ANPRM will be accepted until September 28. The final rule

Companies and individuals alike have struggled to keep on top of the increased sanctions risks emanating from the heightening of international tensions in recent years. Recently, two English law cases, Havila Kystruten AS and Others v. STLC Europe Twenty Three Leasing Ltd and Another [2022] EWHC 3166 (Comm) (referred to as the Havila case) and

Amid heightened tensions between the U.S. and China, the Ministry of Commerce of the People’s Republic of China recently announced measures to add Lockheed Martin Corporation and Raytheon Missiles & Defense to its Unreliable Entity List, which, amongst other things, bars both U.S. companies from import and export trade with China and any new investment