Investment Enforcement

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On November 15, 2022, the Securities and Exchange Commission announced the results of its Division of Enforcement activity for the 2022 fiscal year.  Actions speak louder than words and—while the Commission issued several significant “proposed rules” during the past year, including enhanced disclosures about Environmental, Social, and Governance (ESG) investment practices and new disclosure rules…

New guidelines may portend increased enforcement over foreign investment that implicates U.S. national-security concerns

On October 20, 2022, the Department of Treasury, which houses the Committee on Foreign Investment in the United States (CFIUS), adopted the first-ever CFIUS Enforcement and Penalty Guidelines. The guidelines represent the first written guidance related to how CFIUS will…