Archive:2025

1
Trump Administration Directs CFIUS to Tighten Restrictions on Investment From Certain Countries While Easing National Security Reviews of Investments From Allies and Partners
2
EU Sanctions—Article 8a “Best Efforts” Explained
3
New Executive Order Bolsters the Nation’s Cyber Defenses
4
New US Sanctions Target Russia’s Energy Sector
5
Preparing for New Trump Tariffs: 10 Approaches

Trump Administration Directs CFIUS to Tighten Restrictions on Investment From Certain Countries While Easing National Security Reviews of Investments From Allies and Partners

By: Guillermo S. Christensen, Steven F. Hill, Brian J. Hopkins, Dave R. Allman, Nate B. Bolin, and Jeffrey Orenstein

On 21 February 2025, President Donald J. Trump issued the America First Investment Policy, directing the Committee on Foreign Investment in the United States (CFIUS) to adjust its approach to foreign investments. This policy aims to facilitate investments from allied nations while imposing stricter reviews on investments from adversarial countries, particularly China.

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EU Sanctions—Article 8a “Best Efforts” Explained

By: Michael E. Ruck and Petr Bartoš

On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. A notable addition was made to Article 8a of Council Regulation (EU) No 833/2014, which introduced the requirement that EU operators “undertake their best efforts to ensure that any legal person, entity or body established outside the Union that they own or control does not participate in activities that undermine the restrictive measures provided for in [the] Regulation.” A similar clause has also been included in the Belarus sanctions framework.

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New Executive Order Bolsters the Nation’s Cyber Defenses

By: Sheila Armstrong, Corey Bieber, Guillermo Christensen, Brian Hopkins, and J.D. Koesters

In a significant move to bolster the United States’ cybersecurity framework, President Biden issued an executive order (EO) on 16 January 2025 titled “Strengthening and Promoting Innovation in the Nation’s Cybersecurity” days before leaving the White House. This comprehensive directive outlines measures designed to enhance the security of federal systems, improve transparency in third-party software supply chains, and leverage emerging technologies to fortify cyber defenses.

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New US Sanctions Target Russia’s Energy Sector

By: Nate Bolin, Jeffrey Orenstein, Myeong Park, and Brian Hopkins

On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of new sanctions targeting Russia’s energy sector. In an effort to curtail Russia’s oil revenue and ability to evade US sanctions, OFAC issued: (1) a Determination authorizing sanctions on parties operating in Russia’s energy sector; (2) a Determination banning US petroleum services to Russia; and (3) blocking sanctions against oil and gas majors, vessels in the so-called “shadow fleet,” certain traders of Russian oil, Russian maritime insurers, and Russian oilfield service providers.

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