Alexis Early

Alexis Early

Alexis Early counsels multinational corporations, financial institutions, and individuals on economic sanctions compliance, the release of erroneously blocked assets, export controls, and CFIUS national security reviews of inbound foreign investments, and the impact of legislation pending before Congress.  She has experience representing clients in compliance and enforcement proceedings before the Treasury Department, State Department, Commerce Department, and Department of Homeland Security.  Prior to joining Steptoe, Ms. Early advised corporations and foreign sovereigns on international trade, defense cooperation, and rule of law issues, and advocated on their behalf before Congress.

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UN and EU North Korea Sanctions: Impacts on European and Cross-Border Trade

As tensions continue to escalate between the United States and North Korea, and President Donald Trump and Kim Jong-Un trade increasingly tense lobs, the United Nations, the EU, the United States, and other countries continue to impose further stringent sanctions against North Korea to a breaking point (for details on UN Security Council Resolution 2375 … Continue Reading

Congress Scrutinizes Foreign Investment, Fires Warning Shots at China and Silicon Valley

During a November 8 press conference announcing the introduction of the Foreign Investment Risk Review Modernization Act (“FIRRMA”) while President Trump met with President Xi Jinping in China, co-sponsor and Senate Majority Whip John Cornyn (R-TX) summed up the impetus for the bipartisan, bicameral bill in five words: “China is eating our lunch.” In the … Continue Reading

Steptoe Cyberlaw Podcast: Update on Possible CFIUS Reform Legislation

On October 30, 2017, Brian Egan and Alexis Early were featured on Steptoe’s Cyberlaw Podcast to discuss the possible introduction of CFIUS reform legislation.  They discuss the rumored provisions in Sen. John Cornyn’s (R-TX) Foreign Investment Risk Review Modernization Act and what it means for US sellers and foreign buyers.… Continue Reading

Congress Continues Bipartisan Focus on Sanctions Legislation

The House of Representatives was the scene of a flurry of sanctions-related activity this week, as the lower chamber passed new sanctions measures related to North Korea, Iran, and Hizballah. The bipartisan consensus on sanctions policy in the House continued, with three of the bills passing by unanimous voice vote and the other two bills … Continue Reading

CFIUS Releases Long-Awaited 2015 Annual Report

The Trump administration is making significant changes to longstanding trade policies. Among the flashpoints is the Committee on Foreign Investment in the United States (“CFIUS”), responsible for national security reviews of certain inbound foreign investments.  Since President Trump assumed office, the Committee has taken an increasingly critical eye to many transactions, scuttling an increasing number … Continue Reading

European Commission Proposes EU-Wide Scheme for Screening Foreign Investments in the EU

The European Commission issued on September 13th 2017 a Proposal for a Regulation establishing a framework on the screening of foreign direct investments (FDI) into the EU. The objective of this proposal is two-fold: pushing third countries to open their domestic markets to EU investments, and protecting EU assets against foreign takeovers detrimental to the … Continue Reading

FinCEN, OFAC Increase Coordination of Enforcement Activities

Recent joint activity by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC), including joint actions against Venezuela and North Korea, suggest that the two Treasury agencies are increasing coordination to tackle financial and other crimes. On September 20, 2017, FinCEN issued an advisory which detailed widespread corruption in Venezuela, … Continue Reading

Open Investment? Trump Blocks Lattice Semiconductor/Canyon Bridge Deal, Following CFIUS Recommendation

As many CFIUS-watchers were expecting, the President has just blocked the Lattice Semiconductor/Canyon Bridge deal.  CFIUS recommended that the President take this action because of national security concerns, and no President has refused to follow such a blocking recommendation by CFIUS. In most cases, where CFIUS has made such a recommendation, the parties have abandoned … Continue Reading

UPDATE: Congress Passes Sweeping Iran, Russia, and North Korea Sanctions Legislation

On July 27, the Senate passed 98-2 the Countering America’s Adversaries Through Sanctions Act (HR 3364), which previously passed the House 419-3 on July 25, setting up  a showdown with President Trump. This bill is an omnibus of three separate sanctions measures: the Countering Iran’s Destabilizing Activities Act (“CIDAA”), the Countering Russian Influence in Europe … Continue Reading

US Ratchets up Pressure on North Korea by Targeting Chinese Supporters

President Trump’s recent exasperated tweet at China – suggesting China is not doing enough to stop North Korea’s nuclear efforts and rogue behavior – was followed last week by financial sanctions on Chinese supporters of North Korea.  On June 29, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) placed on its list of Specially … Continue Reading

OFAC Removes Burmese Sanctions Regulations

On June 16, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it removed the Burmese Sanctions Regulations (“BSR”) from the Code of Federal Regulations.  This removal is the culmination of actions taken by the Obama Administration in October 2016 to terminate the national emergency with respect to Myanmar (EO … Continue Reading

Trump Administration Considers National Security Implications of Steel Imports

On April 19, the Trump administration took action under a rarely-used provision of the Trade Expansion Act of 1962, allowing the United States to impose tariffs if it determines that certain imports pose a national security threat.  Acting under section 232 of the Trade Expansion Act, the Department of Commerce announced the start of an … Continue Reading

Congressional CFIUS Round-Up

The Committee on Foreign Investment in the United States (“CFIUS”) review process has long been a creature of the executive branch, but members of the House and Senate are increasingly trying to exert their influence over CFIUS in 2017—and it is Chinese and Russian investors who are first and foremost in Congress’s sights. On April … Continue Reading

New Iran Sanctions Bills Backed by Bipartisan Group of Key Legislators

On March 23, 2017, members of Congress introduced two new bills aimed at increasing non-nuclear sanctions against Iran. While several Iran sanctions bills have been introduced since the start of the year, these newly introduced bills are particularly notable due to their bipartisan support from an influential group of legislators. The bills represent legislative compromises … Continue Reading

ZTE Enters Multi-Agency Settlement to Resolve Sanctions and Export Controls Allegations

On March 8, 2016, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added major Chinese telecommunications company Zhongxing Telecommunications Equipment (“ZTE”) and three ZTE affiliates to the BIS Entity List, alleging that the ZTE entities developed a scheme to re-export controlled items to Iran in violation of US export controls and sanctions … Continue Reading

Generation Shift: Recent Developments in US-China Business Relations and the Path Ahead Under President-elect Trump

The US-China relationship is conceivably the most significant and complex bilateral relationship of the early 21st century, largely because China is the greatest US trading partner that is not a strategic ally.  US-China competition regarding security and global influence can drive innovative solutions or hamper trade and other areas of cooperation.  Please see our advisory … Continue Reading

Groundbreaking Russia Sanctions Bill Introduced in the Senate

A bipartisan group of US Senators introduced a bill on January 11, 2017 – the Countering Russian Hostilities Act of 2017 – that would impose unprecedented sanctions on Russia and persons and entities conducting certain types of business involving Russia.  This bill would codify into law most of the existing sanctions targeting Russia, making it … Continue Reading

What to Expect for Economic Sanctions Under President Trump?

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he … Continue Reading

Iran Sanctions Extension Act Becomes Law without President Obama’s Signature

On December 15, 2016, the White House Press Secretary released a statement that President Obama would allow the Iran Sanctions Extension Act (H.R. 6297) to become law, but that the President declined to sign it.  This bill extends the current Iran Sanctions Act (ISA) through December 31, 2026 and passed Congress with overwhelming support, passing the … Continue Reading

BIS Again Extends ZTE Temporary General License

On November 18, 2016, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it extended its temporary general license for exports, reexports, and in-country transfers to Zhongxing Telecommunications Equipment Corporation (ZTE Corporation) and ZTE Kangxun.  The temporary general license benefitting these two ZTE entities was scheduled to expire on November 27, 2016, … Continue Reading

Two Questions and Partial Answers About What a Trump Administration Could Mean for CFIUS

The Committee on Foreign Investment in the United States (“CFIUS”) is a powerful tool of the executive branch.  CFIUS effectively can impose conditions on, block, or even unwind foreign investments in U.S. companies.  But the tool has been wielded, thus far, only to safeguard U.S. national security. Two common questions about CFIUS, in view of … Continue Reading

Deadline Approaches for Facility Security Clearance Holders to Implement Insider Threat Procedures

As Steptoe previously reported, May 2016 the DoD published updates to the National Industrial Security Operating Manual (“NISPOM,” Change 2 to DoD 5220.22-M) and an accompanying Industrial Security Letter requiring government contractors holding a facility security clearance (“FCL”) to establish or maintain a written policy by November 30, 2016 to detect, deter, and mitigate insider … Continue Reading

How the 2016 Election Will Impact Public Policy Developments

Sunday’s presidential town hall debate was the second of three opportunities for candidates Donald Trump and Hillary Clinton to make their case to the American electorate.  In addition to the discussion of personal and character issues, the candidates touched on a range of policy issues, including tax policy, financial services, energy, and international trade.  The … Continue Reading

When is the Right Time to Make a CFIUS Filing?

Foreign investors in US companies often must consider multiple regulatory issues.  Among those is whether to seek clearance from the Committee on Foreign Investment in the United States, or CFIUS.  A related question is when to file with CFIUS.  Comparatively little guidance is available on the latter question.  To learn more about whether and when … Continue Reading
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