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- Alan P. Larson
Alan P. Larson

Alan Larson provides clients with strategic advice, counseling and representation at the intersection of international business and public policy. A Ph.D. economist, decorated diplomat and non-lawyer, Mr. Larson advises clients on high stakes international challenges. His trouble shooting takes him to all parts of the world. His practice encompasses international investment and acquisitions; sanctions and trade compliance; international energy transactions, international aviation and international trade. He has helped win approval of the U.S. Committee on Foreign Investment in the U.S. (CFIUS) for some of the highest profile foreign investments in the United States, including several by state-owned companies and sovereign wealth funds.
Mr. Larson co-leads Covington's innovative Global Problem Solving (GPS) initiative. GPS combines expert legal work with sophisticated policy strategies to solve client's most complex and consequential international challenges. He is Chairman of Coalition for Integrity and a Board Member of Helping Children Worldwide. He previously served in the State Department's top two economic policy jobs, as Under Secretary of State for Economics and Assistant Secretary of State for Economic and Business Affairs, as well as Ambassador to the OECD. He is a Career Ambassador, the State Department’s highest honor.
- Provides strategic advice to a young international oil company active in frontier regions.
- Provides strategic advice to a U.S. company facing a criminal investigation in a foreign jurisdiction.
- Resolved several high value international investment disputes in the energy sector.
- Advised CEOs and Boards of Directors on sanctions compliance issues regarding Iran and Libya.
- Advised over a dozen firms on Iran sanctions issues and represented several before U.S. government agencies.
- Advised dozens of firms on Russia sanctions issues.
- Represented in the CFIUS process many firms, including SOEs and sovereign wealth funds, that successfully acquired sensitive assets in the U.S.
- Traveled to a Central Asian capital to represent before the government the interests an oil company and two incarcerated employees.
- Advised firms on sanctions compliance and conflicting oil claims in Southern Sudan, Burma and Cuba.
- Advised firms on regulatory issues and policy issues in China and India.
- Represented, before the President and Prime Minister and of Pakistan, companies seeking stronger intellectual property rights protection.
- Advises on international legal cooperation issues, including extradition and mutual legal assistance.
- Advised an Indonesian firm on international policy issues and a U.S. firm on an Indonesian investigation.
- Won approval of an acquisition of a U.S. agro-business firm by a Japanese investor.
Memberships and Affiliations
- Coalition for Integrity, Chairman of the Board
- Helping Children Worldwide, Board Member
- Co-Chaired private sector advisory panels for Obama Administration on bilateral investment treaties and corporate social responsibility guidelines
Previous Experience
- Department of State, Economic, Business and Agricultural Affairs, Under Secretary of State (1999-2005)
- Department of State, Economic and Business Affairs, Assistant Secretary of State (1996-1999)
- Organization for Economic Cooperation and Development, Ambassador (1990-1993)
January 2021
Recapture of Excess COVID-19 Payroll Tax Credits Addressed in New Regs As the legal, regulatory, and commercial implications of coronavirus COVID-19 continue to evolve, our lawyers and advisors are helping clients navigate the complex considerations that companies around the world are facing and develop plans and strategies in response. Reach out to our ...
December 21, 2020, Covington Alert
On December 18, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a Final Rule (“the Rule”), effective immediately, adding 77 entities to the BIS Entity List. The majority of these entities are in China, and include, among others, the Semiconductor Manufacturing International Corporation (“SMIC”) and the drone company SZ DJI ...
November 16, 2020, Covington Alert
On Thursday, November 12, 2020, President Trump signed an Executive Order (the “Order”) that, beginning on January 11, 2021, will prohibit U.S. persons from transacting in the publicly traded securities of 31 companies that the Department of Defense has identified as “Communist Chinese military companies.” The requirement for the Department of Defense to create ...
September 22, 2020, Covington Alert
On September 15, 2020, the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), published in the Federal Register a final rule (the “Final Rule”) amending the requirement to file with CFIUS certain transactions involving U.S. businesses that produce, design, test, manufacture, fabricate, or develop one or ...
September 21, 2020, Covington Alert
On September 19, 2020, China’s Ministry of Commerce ("MOFCOM") issued regulations that provide new details on the government’s plans for an “Unreliable Entity List” first proposed in May 2019.
August 20, 2020, Covington Alert
The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) released its Annual Report to Congress regarding its review of certain transactions involving foreign investment during 2019. The current Annual Report was released just two and a half months after the previous Annual Report, covering 2018, demonstrating the Committee has ...
July 16, 2020, Covington Alert
In our client alert of May 29, 2020, we reported on the initial U.S. government reaction to the announced intention of China’s legislature, the National People’s Congress (“NPC”), to unilaterally impose national security legislation on Hong Kong. As expected, on June 30, the NPC unanimously adopted the “Law of the People’s Republic of China on Safeguarding ...
June 23, 2020, Covington Alert
On June 22, 2020, President Trump issued a proclamation titled “Proclamation Suspending Entry of Aliens Who Present a Risk to the U.S. Labor Market Following the Coronavirus Outbreak” (“June 22 Proclamation”). The June 22 Proclamation blocks the entry of foreign workers entering the United States on certain nonimmigrant visa categories, including H-1B, H-2B, ...
May 29, 2020, Covington Alert
On May 27, Secretary of State Michael Pompeo certified to Congress pursuant to the Hong Kong Human Rights and Democracy Act of 2019 that "Hong Kong does not continue to warrant treatment under United States laws in the same manner as U.S. laws were applied to Hong Kong before July 1997." In a statement, Secretary Pompeo attributed this action to the announced ...
CFIUS Proposes New Rules Governing Mandatory Filing Requirements for Critical Technology Businesses
May 21, 2020, Covington Alert
On May 21, 2020, the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), published in the Federal Register a proposed rule (the “Proposed Rule”) that would amend the requirements to file with CFIUS certain transactions involving U.S. businesses that produce, design, test, manufacture, fabricate, or develop ...
May 19, 2020, Covington Alert
The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) released its Annual Report to Congress regarding foreign acquisitions of, and investments in, U.S. businesses reviewed by CFIUS in 2018. The Committee also released a table reflecting data on the total number of formal reviews (not declarations) in 2019.
April 29, 2020, Covington Alert
The day we have all been expecting has finally come — CFIUS filing fees are going into effect on May 1, 2020. As discussed in our earlier alert, on March 4, 2020, the Department of the Treasury (“Treasury”) issued a proposed rule regarding CFIUS filing fees, which were authorized under the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). ...
April 23, 2020, Covington Alert
On April 22, 2020, President Trump issued a proclamation titled “Proclamation Suspending Entry of Immigrants Who Present Risk to the U.S. Labor Market During the Economic Recovery Following the COVID-19 Outbreak” (the “Proclamation”). The Proclamation prohibits, for 60 days beginning on April 23, 2020, individuals who are currently outside the United States from ...
April 13, 2020, Global Policy Watch
America’s political leaders overcame political differences to enact $2 trillion in national economic support bill, while the Federal Reserve took historic steps to assure liquidity for the economy to address COVID-19. Important steps for sure, but a bigger challenge lies around the corner. This is a global pandemic causing global economic crisis; the United ...
April 8, 2020, Covington Alert
On Saturday, April 4, 2020, the White House released the long-awaited Executive Order (“EO”) formalizing the “Team Telecom” Process, titled the “Executive Order on Establishing the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector” (“the Committee”). This EO provides, for the first time, formal ...
April 1, 2020, Covington Alert
The scope and scale of recent events is almost inconceivable. All of us —including the Committee on Foreign Investment in the United States (“CFIUS”) — are sailing in uncharted waters. That said, while we may not have all of the answers, we are able to share some insights from the CFIUS front lines regarding how the challenges presented by the COVID-19 pandemic ...
COVID-19 Tariff Relief
March 25, 2020, Covington Alert
USTR may exclude tariffs on Chinese imports related to COVID-19 response In response to COVID-19, the Office of the U.S. Trade Representative ("USTR") announced on March 20, 2020, that it is inviting comments on possible modifications to the list of goods from China subjected to additional tariffs under Section 301 of the Trade Act of 1974 (“Section 301 ...
March 9, 2020, Covington Alert
As we reported this past Friday, on March 6, 2020, President Trump issued only the sixth Executive Order (the “Order”) in history formally prohibiting the acquisition of a U.S. business by a foreign person, pursuant to the authorities that allow the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) to review foreign mergers and ...
The Department of the Treasury Issues Proposed Regulations to Impose Fees for Certain CFIUS Filings
March 4, 2020, Covington Alert
Filing fees — one of the long awaited (and dreaded) innovations of the 2018 Foreign Investment Risk Review Modernization Act (FIRRMA) that has transformed the Committee on Foreign Investment in the United States (CFIUS) — have finally arrived. For more than 30 years, transactions could be submitted to CFIUS for review without a fee payable to the federal ...
February 5, 2020
WASHINGTON—Kimberly Breier, the U.S. Department of State’s former top diplomat for Latin America, has joined Covington as a senior advisor. Ms. Breier most recently served as Assistant Secretary of State for Western Hemisphere Affairs, the United States’ top diplomat for the Western Hemisphere. She led the State Department’s policy formation, oversaw U.S. ...
January 17, 2020, Covington Alert
On January 15, 2020, President Trump and Chinese Vice Premier Liu He signed the much-anticipated “Phase One” trade agreement between the U.S. and China. Set to take effect no later than February 14, 2020, the “Economic and Trade Agreement Between the United States of America and the People’s Republic of China” (the “Agreement”) is the first formal accord ...
January 14, 2020, Covington Alert
The institutional transformation of the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) that commenced more than two years ago with the introduction in Congress of the Foreign Investment Risk Review Modernization Act (FIRRMA) now is largely complete with the issuance of the highly anticipated final regulations implementing ...
December 9, 2019
The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) released its Annual Report to Congress regarding foreign acquisitions of U.S. businesses reviewed by CFIUS in 2016 and 2017, a combined report covering the final year of the Obama administration and the first of the Trump administration. The report also reflects the crucial ...
October 21, 2019, Covington Alert
On October 18, 2019, the U.S. Administration announced the launch of a new product-specific exclusion request process for tariffs on approximately $112 billion in Chinese imports that were imposed on September 1, 2019. The exclusion process will close on January 31, 2020, and its requirements are similar to those applicable to the latest exclusion process for an ...
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”).
April 2020
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 Publishes Final Rule Governing Mandatory Filing Requirements for Critical Technology Businesses, Covington ...
September 27, 2019
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 set of regulations to govern ...
September 20, 2019
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. On Tuesday of this past week, CFIUS issued its anticipated proposed final regulations (“Regulations”) to implement the Foreign Investment Risk Review Modernization ...
September 10, 2019
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”). FIRRMA transformed CFIUS’s authorities, but many of the most ...
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”). Approximately nine months after the enactment of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”) and six months into the Critical Technology Pilot Program (“the Pilot ...
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, 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 ...
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 ...
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 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.
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 ...
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
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 ...
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 ...
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 ...
Newly-Released CFIUS Annual Report for 2015 Foreshadows Heightened Scrutiny of Foreign Investment
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 ...
Presidential Report Recommends U.S. Action to Counter Chinese Policies in the Semiconductor Industry
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 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 ...
July 18, 2014, Covington E-Alert
July 11, 2014, Covington Advisory
US China Investment Pact Talks May Spur Market Reform
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 ...
May 19, 2014, The Wall Street Journal
Covington's Alan Larson and Mark Plotkin are quoted regarding Chinese investment in U.S. infrastructure
April 15, 2014, Covington E-Alert
March 4, 2014, 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
Covington to Host US-China Dialogue at Shanghai Expo
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
- Secretary of State’s Distinguished Service Award, Department of State (2005)
- Career Ambassador, U.S. Department of State (2004)

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