Overview
Steptoe partners Brian Fleming and Evan Abrams, along with associate Ryan Pereira, authored an article for Export Compliance Manager titled "Treasury Finalizes Outbound Investment Regime." The article discusses the recently issued regulations by the US Department of the Treasury prohibiting or requiring notification of certain investments involving China (including Hong Kong and Macau) that involve sensitive technologies and products in the semiconductor, quantum, and AI sectors. The regulations provide several factors that Treasury will consider in determining if all reasonable steps have been taken, and US persons with controlled foreign entities will want to review these factors and ensure they have been fully implemented to the degree relevant.
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