Special Counsel | Corporate
On June 21, 2024, the U.S. Department of Treasury (“Treasury”) issued a notice of proposed rulemaking (“Proposed Rule”) that would regulate certain U.S. transactions with persons of a country of concern involved in the semiconductor and microelectronics, quantum information technology and artificial intelligence (AI) sectors, as authorized by Executive Order 14105 (“EO 14105”). The Proposed Rule maintains the two-tiered regulatory framework announced in the advance notice of proposed rulemaking released in August 2023 that would prohibit entirely some transactions and require notification to the Department of the Treasury for others. Given its scope, the Proposed Rule has the potential to impact U.S. investors, including investment funds, in their investment decisions and approach to deal diligence generally.
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