In an Advance Notice of Proposed Rulemaking (ANPRM) published in the Federal Register on Monday, March 29, 2021, Commerce announced that it is soliciting public comment on a licensing process for companies seeking pre-clearance for information and communications technology and services (ICTS) transactions subject to Commerce’s broad new authority to block or unwind such transactions, as implemented in the interim final rule, “Securing the Information and Communications Technology and Services Supply Chain.” That interim final rule, which was published on January 19, 2021, became effective on Monday, March 22, 2021, and broadly defines transactions to include acquisition, importation, transfer, installation, dealing in or use of ICTS. We previously discussed that interim final rule here.
Continue Reading Commerce Publishes ANPRM Seeking Comment on the Licensing Process for ICTS Transactions
Jana del-Cerro
Not Your Parents’ IT: New Interim Rule to Scrutinize Acquisition of IT Products and Services from Foreign Adversaries
Today, Commerce has published an interim final rule (IR) which, effective March 22, 2021, will implement the May 15, 2019 Executive Order 13873 that relied on the International Emergency Economic Powers Act (IEEPA) to authorize sweeping power to block or undo any transaction – including use, purchases or importation – of virtually any “information and…
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Introducing the Export Controls Classroom
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Government Contracts: CFIUS Expands Types of Transactions Subject to Pre-Closing Mandatory Declarations
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Pay-to-Play 2: CFIUS Filing Fees Go Into Effect May 1, 2020
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Coronavirus Update: FEMA Allocates Certain Scarce PPE for Domestic Use and Restricts Exports
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Pay to Play: CFIUS Implementing Fees for Submissions of Voluntary Notices
On March 4, 2020, the Department of Treasury released a proposed rule to implement section 1723 of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) and require filing fees on voluntary notices to the Committee on Foreign Investment in the United States (CFIUS) for transactions that exceed $500,000. No fee will be required…
OOPS 2017 Preview: International Contracting: Competing Policies Roil International Procurement
The Trump Administration’s first 100 days shed little light on how it will reconcile an America First trade policy with insistence on more robust defense spending by our allies. On May 5, 2017, at 8:30 AM Eastern, Crowell & Moring attorneys Adelicia Cliffe, Alan Gourley, Yuan Zhou, and Jana del-Cerro will lead a discussion highlighting…
C&M Lawyers Conduct Live Webinar on Export Controls, Economic and Trade Sanctions on Thursday, August 11th
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