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ARTICLE · 06 JANUARY 2025

Trade Matters

Lowenstein Sandler LLP
Lowenstein Sandler LLP
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Lowenstein Sandler LLP

Lowenstein Sandler LLP

Lowenstein Sandler LLP is a national law firm with over 400 lawyers based in New York, Palo Alto,...

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As we wrote previously, the U.S. Department of the Treasury has issued a final rule that takes effect on December 26 that will dramatically raise the Committee on Foreign Investment...

United StatesInternational Law
Doreen Edelman
Doreen Edelman
Abbey Baker
Abbey Baker
Kei Komuro
Kei Komuro
Megan Bodie
Megan Bodie

1. CFIUS Penalties Will Increase Maximum Civil Penalty to $5 Million or the Value of the Transaction

As we wrote previously, the U.S. Department of the Treasury has issued a final rule that takes effect on December 26 that will dramatically raise the Committee on Foreign Investment in the United States (CFIUS) penalties from $250,000 to the greater of $5 million or the value of the transaction per violation. CFIUS also will have increased investigative powers to investigate non-notified transactions. Please consider an initial CFIUS review early in any new transaction planning if you have foreign investors, even if they are limited partners.

2. $14.6 Million OFAC Penalty for Foreign Supplier That Caused a US Company to Violate Iran Sanctions

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