As we covered in October, CFIUS has published enforcement guidelines, but has yet to levy any fines. So we asked readers to predict when we’d see the first penalty for “failure to file a mandatory declaration or notice.” The line was set at April Fool’s Day, 2023. Readers took the “over.” Results inside.
In one of Paul Rosen’s first acts as head of CFIUS, the Treasury Department has issued formal enforcement and penalty guidelines. The guidance, promised more than two years ago, includes an interesting list of factors that CFIUS considers when determining penalties. Details and guidance inside.
A leader of the DoJ’s National Security Division has provided some great details on compliance and enforcement of mitigation agreements. Of note: The DoJ conducted 35 site visits last year to monitor compliance. Details, key takeaways, the full speech, and contact information are inside.