“Every export—every single one—has a related financial transaction”Continue Reading Banks Do Export, Too: New BIS Guidance Tags Financial Firms with Export Compliance Responsibilities
The Waiting Game: When, Why, and How to File with CFIUS in a New Era of Investment Scrutiny
The other day I spoke to a colleague at the U.S. Department of the Treasury who works in the Office of Investment Security and said, “I heard CFIUS filings were going to break last year’s record total.” He just laughed. He said the OIS received one hundred and seventy-some filings in 2016, the most they had ever received in a year.
This year, only in November, they were over 225 submissions!
Of course, all of this was just talk and should not be relied on for statistical analysis. But it gives you a good idea of the flood of CFIUS filings that the Committee is now tasked with reviewing. While my contact was sanguine on the possibility of adding some new folks soon to his office soon, he noted that the OIS staff – whom he called the best of the best – has not yet been increased to meet the surge in demand.
So what does this mean for your inbound investment into the United States? We explore that question and provide a few tips below. In addition to a present snapshot of CFIUS, we have a look at the future of CFIUS as a proposed Senate bill aims to increase scrutiny on foreign investment.
Continue Reading The Waiting Game: When, Why, and How to File with CFIUS in a New Era of Investment Scrutiny
New Business Opportunities in Iran! But Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for Good Reason
Highlights:
- Sanctions relief presents new business opportunities with Iran
- Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies
- The line between permitted and prohibited financial transactions by non-U.S. banks is not clear
- Careful advice of counsel is critical
Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?
After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately, since the end of sanctions is a long way away.
Continue Reading Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?