by Rachel K. Alpert, Shoba Pillay, and Emily A. Merrifield
On April 29, 2021, the Boston U.S. Attorney’s Office announced that SAP SE, a multinational software company headquartered in Walldorf, Germany, entered into the first non-prosecution agreement under the Department of Justice’s (DOJ) revised Voluntary Self-Disclosure Policy, announced on December 13, 2019. Continue reading
by Rachel K. Alpert, Julian J. Ginos, and Rebecca Fate
Last month’s confirmation hearings for Treasury Secretary Janet Yellen and Secretary of State Antony Blinken have shed more light on the Biden administration’s approach to key sanctions programs. At a high level, human rights considerations are expected to loom larger in sanctions strategy going forward. Other systemic changes may be afoot as well; Yellen plans to direct Adewale Adeyemo, the nominee for Deputy Treasury Secretary, to conduct an overall review of U.S. sanctions policy, and the Biden administration has also ordered a review of sanctions as possible hindrances to COVID-19 response efforts. Below are seven areas of interest along with key takeaways thus far.
by Les P. Carnegie, John H. Chory, Benjamin A. Potter, Rachel K. Alpert, and Erica S. Koenig
On February 13, 2020, two Final Rules published by the US Treasury Department implementing changes to the foreign investment review process administered by the Committee on Foreign Investment in the United States (CFIUS) became effective. The Final Rules include provisions pertaining to certain investments in the United States by foreign persons (PDF: 479 KB), as well as provisions pertaining to certain transactions by foreign persons involving real estate in the United States (PDF: 406 KB). This post provides an overview of the areas of the Final Rules that may affect technology companies and their investors.[1]