by Chase Kaniecki, Samuel H. Chang, B.J. Altvater, and Ryan Brown
Left to right: Chase Kaniecki, Samuel H. Chang, B.J. Altvater, and Ryan Brown (Photos courtesy of Cleary Gottlieb Steen & Hamilton LLP)
On October 28, 2024, the U.S. Department of the Treasury (“Treasury”) issued a long-awaited Final Rule (the “Final Rule”) implementing the U.S. Outbound Investment Security Program (the “Program”).[1] Under the Program, effective January 2, 2025, U.S. persons will be prohibited from engaging in, or required to notify Treasury regarding, a broad range of transactions involving entities engaged in certain activities relating to semiconductors and microelectronics, quantum information technologies, and artificial intelligence (“AI”) systems in “countries of concern” (presently limited to China, Hong Kong, and Macau).