Alan P. Larson

October 10, 2019, Covington Alert

On October 9, the U.S. Department of Commerce issued a Final Rule adding 20 Chinese government entities and eight Chinese private sector entities (“Listed Entities”) to the Entity List maintained by the Commerce Department’s Bureau of Industry and Security (“BIS”).

September 27, 2019, Covington Alert

As we reported previously, last week the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) issued its proposed final regulations (“Regulations”) to implement its expanded authorities under the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). In doing so, CFIUS bifurcated the rulemaking process, proposing one ...

September 20, 2019, Covington Alert

For over 30 years, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) focused on a narrow subset of M&A transactions and investments. That era is coming to an end.

September 10, 2019, Covington Alert

The U.S. Department of the Treasury is expected to issue soon proposed regulations implementing the Foreign Investment Risk Review Modernization Act (“FIRRMA”), legislation enacted in August 2018 that reformed the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”).

August 30, 2019, Covington Alert

On August 27 and 29, 2019, the U.S. Administration released notices concerning increases in certain tariffs on Chinese imports, marking the latest escalation in bilateral trade frictions.

August 28, 2019, Covington Alert

On August 23, 2019, President Donald J. Trump tweeted: "Our great American companies are hereby ordered to immediately start looking for an alternative to China, including bringing . . . your companies HOME and making your products in the USA."

August 20, 2019, Covington Alert

On August 19, 2019, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a Final Rule adding 46 non-U.S. affiliates of Huawei Technologies Co., Ltd. (“Huawei”) to the Entity List and extended, through November 18, 2019, a revised Temporary General License (“TGL”) authorizing certain transactions with Huawei and listed Huawei entities.

August 8, 2019, Covington Alert

On August 5, 2019, President Trump issued Executive Order 13884 imposing comprehensive sanctions against the Government of Venezuela. Specifically, the Executive Order blocks all property and interests in property of the Government of Venezuela that are in or that come into the United States or the possession or control of a U.S. person.

June 21, 2019, Covington Alert

Earlier this week, the Office of the U.S. Trade Representative (USTR) announced a process through which companies can request that their products be excluded from duties imposed on $200 billion in Chinese imports under Section 301 of the Tariff Act of 1974 (Section 301). Tariffs on these imports have been in effect since September 2018, and recently increased ...

May 14, 2019, Covington Alert

On May 13, days after increasing tariffs on $200 billion in Chinese imports, the U.S. Administration proposed imposing an additional 25 percent tariff on a new list of $300 billion in Chinese imports. The Administration cited China’s “failure to meaningfully address” problematic intellectual property (IP) practices and its retaliatory responses to U.S. tariffs ...

May 8, 2019, Covington Alert

On May 8, the U.S. Administration confirmed its intent to increase tariffs on $200 billion in Chinese imports from 10 percent to 25 percent, effective Friday, May 10, 2019, and establish a process for requesting exclusions from these tariffs. As justification for these actions, the Administration cites the “lack of progress in discussions with China” and ...

May 7, 2019, Covington Alert

We are writing to provide an update on the current trends and operations of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”).

April 25, 2019, Covington Alert

The Trump Administration has announced multiple U.S. sanctions measures over the past several weeks, further tightening the sanctions on Iran and imposing additional measures on Venezuela and its allies, Cuba and Nicaragua.

April 25, 2019

WASHINGTON—Daniel Feldman has joined Covington’s Global Problem Solving group in Washington. A former Special Representative for Afghanistan and Pakistan at the U.S. Department of State, Ambassador Feldman was a principal advisor to Secretaries of State John Kerry and Hillary Rodham Clinton regarding Afghanistan, Pakistan, and broader South, Central, and East ...

April 25, 2019, Bloomberg Law

Bloomberg Law highlighted Covington's Global Problem Solving team and the efforts of the lawyers who make the capability possible.   Sebastian Vos said the group doesn’t just work on problems for clients, but tries to use its resources to anticipate what problems could arise in the future and craft resolutions for them. “We help unlock a situation where a ...

February 19, 2019, Covington Alert

Late last week, President Trump signed an appropriations bill to keep the government funded. In its Joint Explanatory Statement accompanying this legislation, Congress directed the Trump Administration to establish an exclusion request process for tariffs on $200 billion in Chinese imports by March 17, 2019, in line with the process provided for prior rounds of ...

January 29, 2019, Covington Alert

December 3, 2018, Covington Alert

On December 1, during a working dinner meeting in Buenos Aires following the G20 Summit, U.S. President Donald J. Trump and Chinese President Xi Jinping agreed to temporarily ease trade tensions as both sides continue negotiating over longer-term solutions to U.S. concerns about bilateral economic relations.

November 20, 2018, Covington Alert

On November 19, 2018, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) released an Advance Notice of Proposed Rulemaking (“ANPRM”) requesting public comment on the criteria to identify emerging technologies essential to U.S. national security. The comments will inform the interagency process that was authorized under the Export Control ...

November 6, 2018, Covington Alert

The Trump Administration yesterday completed the reimposition of sanctions against Iran that previously were suspended as part of the 2015 multilateral nuclear agreement, known as the Joint Comprehensive Plan of Action (“JCPOA”).

October 11, 2018, Covington Alert

Summary On October 10, the U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), issued interim rules (the “Interim Rules”) that update the CFIUS regulations to address certain definitional and procedural aspects of the Foreign Investment Risk Review Modernization Act (“FIRRMA”) and, for the first time, ...

September 18, 2018, Covington Alert

On September 17, 2018, the Office of the U.S. Trade Representative (USTR) released its final list of approximately $200 billion in Chinese imports subject to an additional ad valorem tariff. The final list, which covers 5,745 product categories, will take effect on September 24, 2018.

August 30, 2018, Covington Alert

On August 27, 2018, the Department of State imposed sanctions against Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) in response to Russia’s use of a chemical nerve agent against a UK citizen.

August 13, 2018, Covington Alert

Earlier today, President Donald Trump signed into law the Foreign Investment Risk Review Modernization Act (FIRRMA) as part of the John S. McCain National Defense Authorization Act. As we have previously reported, FIRRMA will transform the jurisdiction, authority, and operation of the Committee on Foreign Investment in the United States (CFIUS). Our previous ...

August 8, 2018

The Trump Administration has released its final list of approximately $16 billion in Chinese imports that will be subject to an additional 25 percent ad valorem tariff, which will go into effect on August 23, 2018. The Administration has announced that it will provide an opportunity to request that "particular products" subject to the additional duties be ...

August 8, 2018, Covington Alert

On August 6, 2018, President Trump issued Executive Order 13846 (the “Executive Order”) that re-imposes -- and to a limited extent broadens the scope of -- certain U.S. secondary sanctions targeting Iran that had been suspended in January 2016 pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) with Iran.

July 30, 2018, Covington Alert

On July 23, the final text of the Export Control Reform Act of 2018 (“ECRA”) was released as part of the Conference Report to accompany the National Defense Authorization Act (“NDAA”) for fiscal year 2019. The NDAA is a must-pass piece of legislation that authorizes funding for the Department of Defense, and we expect it to be enacted and signed within the next ...

July 25, 2018, Covington Alert

Summary  For over a year, we have reported to our clients as the U.S. government considered and developed legislation that would fundamentally reform the operations of the Committee on Foreign Investment in the United States (CFIUS). That effort has been driven by concerns about risks arising from evolving foreign investment composition and business ...

July 11, 2018, Covington Alert

Last night, the Office of the U.S. Trade Representative (“USTR”) released a new proposed list of $200 billion worth of products from China that could face an additional 10 percent ad valorem tariff. The list covers 6,031 product categories, including a multitude of consumer goods such as luggage, tires, furniture, apparel, mattresses, household goods, components ...

July 10, 2018, Covington Alert

As anticipated, an additional 25 percentage point ad valorem tariff on $34 billion worth of Chinese imports into the United States (covering 818 product categories in sectors including aerospace, information communication technology, machinery, and medical instruments) went into effect on July 6, 2018.

July 2, 2018, Covington Alert

In furtherance of President Trump’s May 8, 2018 announcement that the United States is withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) (discussed in our recent alert), on June 27 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several changes to the U.S. sanctions against Iran.

June 27, 2018, Covington Alert

We write to report on two important developments regarding the Foreign Investment Risk Review Modernization Act (FIRRMA), a bi-partisan effort to reform the Committee on Foreign Investment in the United States (CFIUS), and the broader policy debate within the U.S. government on regulatory mechanisms to address foreign investment, particularly from China. On June ...

June 15, 2018, Covington Alert

As anticipated, the Trump Administration today released its final list of Chinese imports subject to an additional 25 percent ad valorem tariff. The imposition of the tariffs follows the Administration’s determination in March that China’s technology transfer and intellectual property (“IP”) policies are harming U.S. companies, and the submission of public ...

June 15, 2018, Covington Alert

As described in our May 9, 2018, alert, the United States determined on May 8, 2018, to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK, and China.

May 23, 2018, Covington Alert

Summary We are writing to report the latest developments related to legislative reform of the Committee on Foreign Investment in the United States (“CFIUS”). On Tuesday, May 22, 2018, the Senate Committee on Banking, Housing, and Urban Affairs (“Senate Banking Committee” or “SBC”) held a markup of S. 2098—the Foreign Investment Risk Review Modernization Act ...

May 16, 2018, Covington Alert

We are writing to report on the current status of the Foreign Investment Risk Review Modernization Act (“FIRRMA”), legislation to reform the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”). FIRRMA, a bill introduced by Senator John Cornyn (R-TX) in the Senate and Congressman Robert Pittenger (R-NC) in the House, seeks to ...

May 15, 2018, Covington Alert

On May 8, 2018, the United States announced the decision to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK and China.

May 9, 2018, Covington Alert

On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...

May 9, 2018, Covington Alert

On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...

May 8, 2018, Covington Alert

It has been publicly reported that the Trump Administration is considering invoking the International Emergency Economic Powers Act (IEEPA) to further regulate—and in certain areas potentially preclude—Chinese direct investment in the United States, beyond the authorities exercised by the Committee on Foreign Investment in the United States (CFIUS). The prospect ...

May 4, 2018, Covington Alert

The Trump Administration’s senior economic and trade officials held talks with their Chinese counterparts in Beijing, May 3-4. The talks concluded with no agreement, and each side tabled expansive demands that appear well beyond what the other side would be able to accept.

April 30, 2018, Covington Alert

We are writing to report on the latest Congressional hearing related to reform of the Committee on Foreign Investment in the United States (“CFIUS”). On April 26, 2018, the Digital Commerce and Consumer Protection Subcommittee of the House Committee on Energy and Commerce (the “Subcommittee”) held an open hearing entitled “Perspectives on Reform of the CFIUS ...

April 17, 2018, Covington Alert

We are writing to report on the latest Congressional hearing related to reform of the Committee on Foreign Investment in the United States (“CFIUS”). On April 12, 2018, the Monetary Policy and Trade Subcommittee of the House Committee on Financial Services (the “Subcommittee”) held an open hearing entitled “H.R. 4311, the Foreign Investment Risk Review ...

April 6, 2018, Covington Alert

On April 6, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced expanded sanctions against Russian entities and individuals, targeting a number of Russian oligarchs in the energy, banking, and other sectors and companies they own or control, as well as 17 senior Russian government officials.

April 4, 2018, Covington Alert

On April 3, the Trump Administration proposed a list of approximately 1,300 products originating from China that would bear an additional 25 percent ad valorem import tariff and requested public comments on the list, following the Administration’s determination last month that China’s technology transfer and intellectual property (“IP”) policies are harming U.S. ...

March 23, 2018, Global Policy Watch

March 22, 2018 Earlier today, the administration announced its findings that China’s theft of U.S. technologies and intellectual property (“IP”) have caused at least $50 billion in harm to the U.S. economy per year. In response, President Trump issued an order announcing its intent to impose additional tariffs on Chinese imports, curtail Chinese investment ...

March 22, 2018, Covington Alert

Earlier today, the administration announced its findings that China’s theft of U.S. technologies and intellectual property (“IP”) have caused at least $50 billion in harm to the U.S. economy per year.

March 16, 2018, Covington Alert

Summary We are writing to report on the latest Congressional hearings related to reform of the Committee on Foreign Investment in the United States (“CFIUS”) and potential efforts to enhance and reform the U.S. export control regime. Specifically, on March 14, 2018, the House Committee on Foreign Affairs (“House Foreign Affairs Committee” or “HFAC”) held an ...

March 15, 2018, Global Policy Watch

Following the recent U.S. announcement of tariffs on steel and aluminum imports under Section 232 of the Trade Expansion Act of 1962, the United States is now poised to implement trade sanctions against China stemming from an investigation of that country’s intellectual property (“IP”) practices. Such sanctions, which could include significant and maybe even ...

March 15, 2018, Covington Alert

Following the recent U.S. announcement of tariffs on steel and aluminum imports under Section 232 of the Trade Expansion Act of 1962, the United States is now poised to implement trade sanctions against China stemming from an investigation of that country’s intellectual property (“IP”) practices.

March 14, 2018, Law360

Alan Larson recently spoke at a House Committee on Foreign Affairs hearing regarding export control regulations and foreign investment reviews that would protect national security and is quoted in a Law360 article. “It is important to manage the resources of CFIUS efficiently, so that it focuses especially intensely on transactions that are the most complex and ...

March 8, 2018, Covington Alert

On February 15, 2018, House Foreign Affairs Committee Chairman Ed Royce (R-CA) introduced bipartisan legislation—the Export Control Reform Act of 2018 (“ECRA”)⸺to modernize U.S. export control regulation of commercial and dual-use items.

January 26, 2018, Covington Alert

We are writing to report on the latest significant developments in the effort to reform the Committee on Foreign Investment in the United States (“CFIUS”). On January 25, 2018, the Senate Committee on Banking, Housing, and Urban Affairs (“Senate Banking Committee” or “Committee”) held an open hearing entitled “CFIUS Reform: Administration Perspectives on the ...

January 22, 2018, Covington Alert

On January 18, 2018, the Senate Committee on Banking, Housing, and Urban Affairs (“the Committee”) held a hearing to consider the Foreign Investment Risk Review Management Act (FIRRMA), a bill introduced by Senator John Cornyn (R-TX) in the Senate and Congressman Robert Pittenger (R-NC) in the House to reform the Committee on Foreign Investment in the United ...

January 11, 2018, Covington Alert

We are writing to share our report of two Congressional hearings held this week that are relevant to the ongoing legislative discussion concerning potential reform of the Committee on Foreign Investment in the United States (CFIUS).

December 15, 2017, Covington Alert

We write to offer our perspective on two developments relevant to the Committee on Foreign Investment in the United States (“CFIUS”).

November 8, 2017, Covington Alert

During the past two weeks, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State have taken a number of steps toward implementing aspects of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), a major piece of sanctions legislation passed by the U.S. Congress in July and signed by ...

November 8, 2017, Covington Alert

Earlier today, Senator John Cornyn (R-TX), the second-highest-ranking Republican in the Senate, introduced a bill to reform the authority and operation of the Committee on Foreign Investment in the United States (“CFIUS”). The bill is co-sponsored by Senator Dianne Feinstein (D-CA) and Senator Richard Burr (R-NC), the Chairman of the Senate Select Committee on ...

October 17, 2017, Covington Alert

On October 13, President Trump announced that he would no longer certify to Congress that the suspension of U.S. sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) is “appropriate and proportionate” to the steps that Iran has taken to terminate its illicit nuclear program. The President’s much-anticipated announcement does not ...

September 21, 2017, Covington Alert

The Committee on Foreign Investment in the United States (“CFIUS”) this week released its long-awaited Annual Report to Congress regarding foreign acquisitions of U.S. businesses reviewed by CFIUS in 2015. The report provides important data that yields insights into the types of transactions the Committee reviewed and the Committee’s treatment of those ...

September 14, 2017, Covington Alert

We are writing to provide our perspective on two significant developments involving the Committee on Foreign Investment in the United States (“CFIUS”).

July 28, 2017, Covington Alert

Congress has passed and sent to President Trump, for his signature or veto, a bill that would impose significant new sanctions against Russia, Iran, and North Korea. The legislation—the Countering America’s Adversaries Through Sanctions Act—enjoys broad bipartisan support, having passed the U.S. House of Representatives on July 25 by a vote of 419-3, and the ...

July 7, 2017, CNBC

Alan Larson participated in an interview with CNBC to discuss how the G-20 Summit will affect global trade and the world economy. 

June 23, 2017, Covington Alert

We are writing to provide our perspective on recent developments regarding the Committee on Foreign Investment in the United States (“CFIUS”), including the plans of Senator John Cornyn (R-TX) to introduce significant legislation to reform CFIUS, and the operation of CFIUS in the first six months of the administration of President Donald Trump.

January 16, 2017

LONDON—Craig Pollack and Louise Freeman have joined Covington as partners in the firm’s European Dispute Resolution practice resident in London. Mr. Pollack will also serve as co-chair of the firm’s Global Disputes Initiative with former U.S. Attorney General Eric Holder and former U.S. Under Secretary of State Alan Larson.  Mr. Pollack focuses on complex high ...

January 11, 2017, Covington Alert

Late last week, a group of technology industry leaders, researchers, and former policymakers comprising the President’s Council on Science and Technology (“PCAST”) issued a report entitled Ensuring Long-Term U.S. Leadership in Semiconductors. The report concludes that China is seeking to reshape the global semiconductor industry in a manner that threatens U.S. ...

October 17, 2016, Covington Alert

Effective today, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has amended the Cuban Assets Control Regulations (“CACR”) and the U.S. Commerce department’s Bureau of Industry and Security (“BIS”) has amended the Export Administration Regulations (“EAR”) to expand permissible dealings involving Cuba, further easing the longstanding U.S. ...

June 6, 2016, Global Policy Watch

In reaction to the global economic slowdown and commodity price collapse, Saudi Arabia’s leaders have made virtue of necessity in announcing plans for far-reaching economic, educational and related reforms. They aim to innovate and diversify the economy of the Kingdom. The goal is faster growth and job creation, especially in the private sector, in order...… ...

May 12, 2016

WASHINGTON, DC — Covington advised China Molybdenum Co., Ltd (“CMOC”) on certain aspects of its agreement to acquire Freeport-McMoRan Inc.’s indirect 56% Interest in Tenke Fungurume for $2.65 billion in cash plus contingent consideration of up to $120 million. CMOC is primarily engaged in the mining, processing and marketing of mineral products. The acquisition ...

April 28, 2015, Money Laundering Bulletin

April 9, 2015, Global Policy Watch

My colleague Ambassador Stuart Eizenstat has posted a masterful overview of the Framework understanding that Iran and the P5+1 have reached, including an assessment of the issues to be addressed in transforming the Framework into a binding international agreement.  In this posting. I identify five international and diplomatic signposts on which Western companies ...

August 4, 2014, Covington E-Alert

July 18, 2014, Covington E-Alert

July 11, 2014, Covington Advisory

July 11, 2014, Law360

Al Larson is quoted regarding the U.S.-China Bilateral investment pact.  "Laying down a starting point for the exchange of market access offers on investment between two of the globe's largest economies sends a strong message to investors that have been dissatisfied with the lack of access in China ever since the country acceded to the World Trade Organization ...

June 26, 2014, Covington E-Alert

May 19, 2014, The Wall Street Journal

Covington's Alan Larson and Mark Plotkin are quoted regarding Chinese investment in U.S. infrastructure

May 13, 2014, Covington E-Alert

April 29, 2014, Covington E-Alert

April 28, 2014, Covington E-Alert

April 15, 2014, Covington E-Alert

March 5, 2014, Covington E-Alert & Advisory

March 4, 2014, Covington E-Alert

January 22, 2014, Covington E-Alert

December 20, 2013, Covington E-Alert

November 27, 2013, Covington E-Alert

October 25, 2013, Covington Advisory

9/27/2013

WASHINGTON, DC, September 27, 2013 — Marisa Lago, assistant secretary for international markets and development at the U.S. Treasury Department, addressed a symposium held at Covington & Burling earlier in September about trends in Chinese foreign direct investment in America. The symposium, co-hosted with the China General Chamber of Commerce, examined the ...

May 20, 2013

WASHINGTON, DC, May 20, 2013 — The U.S. Department of State recently honored Alan Larson, a senior international policy advisor at Covington & Burling, with its 2013 Foreign Service Cup. The award is given in recognition of a foreign service officer’s career in the foreign service and afterwards on behalf of their communities. Mr. Larson’s distinguished career ...

2/13/2013

WASHINGTON, DC, February 13, 2013 — The Committee on Foreign Investment in the United States (CFIUS) on Tuesday approved CNOOC Ltd.’s bid to acquire the U.S. assets of Canadian energy company Nexen Inc. It was the final regulatory hurdle in the $15.1 billion acquisition, the largest overseas investment ever by a Chinese company. Covington & Burling represented ...

February 2012, Foreign Service Journal

February 2011, Foreign Service Journal

May 19, 2010

WASHINGTON, DC, May 19, 2010 — Against the backdrop of the 2010 Shanghai World Expo, and on the eve of the upcoming round of the Strategic and Economic Dialogue between the US and China, Covington & Burling LLP will co-host a day-long event, “Shaping the US-China Business Relationship” on Friday, May 21. The event will be held at the USA National Pavilion, which ...

February 22, 2010

WASHINGTON, DC, February 22, 2010 — Covington & Burling LLP is pleased to announce that Timothy P. Stratford, who most recently served as Assistant U.S. Trade Representative (USTR) for China Affairs, has joined the firm as a partner. He will be resident in the firm’s Beijing office and will practice in the International Trade and Finance group. Mr. Stratford’s ...

2/11/2009

WASHINGTON, DC, February 11, 2009 — Covington & Burling LLP is pleased to announce that Ambassador John K. Veroneau, who most recently served as Deputy U.S. Trade Representative, has joined the firm’s international practice as a partner. Mr. Veroneau will be resident in Covington’s Washington office. At USTR, Mr. Veroneau had broad supervisory responsibility ...

July 2006, The Bernard and Irene Schwartz Series on American Competitiveness, Council on Foreign Relations

1982, The University of Iowa

October 2018

For over 30 years, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) focused on a narrow subset of M&A transactions and investments. That era is coming to an end.  Covington is monitoring developments:  CFIUS's Proposed Regulations to Implement Expanded Jurisdiction Over Real Estate Transactions, Covington Alert, ...