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There are few bright line tests, and whether a CFIUS filing is required is a fact specific analysis that requires a review of both the foreign parent and the target business. When our Sullivan team reviews a transaction for CFIUS risks we generally prepare a brief memo outlining (i) whether CFIUS has jurisdiction over the transaction and (ii) whether a CFIUS filing is required or, if not required, whether other national security risks are present in the transaction that would make a voluntary CFIUS filing advisable. The type of information that would be pertinent to our analysis is as follows:
Our team has prepared several memos for clients to help analyze CFIUS risk. In the event a CFIUS filing is determined to be mandatory or advisable based on the red flags analysis, we can assist with the filing.
The U.S. Securities and Exchange Commission (“SEC”) announced on July 7, 2026, the creation of the Retail Fraud Working Group, a new initiative within the Division of Enforcement designed to identify and combat fraud targeting main street investors. The announcement formalizes a priority that SEC Enforcement Director David Woodcock previewed in his May 13, 2026, remarks to the Managed Funds Association Legal & Compliance Conference, reflecting the current Commission’s broader
Sullivan & Worcester represented Fattal Hotel Group, owner and operator of 329 hotels across 22 countries and based in Tel Aviv, in its acquisition and financing of The Blakely Hotel in Midtown Manhattan. The acquisition marks the client's first hotel investment in the United States and is a milestone in its evolution from a leading European hospitality operator into a global hotel group. The acquisition was completed on July 7,
Simon Cook, in his role as ITFA's Head of Education, will jointly moderate a Q&A on “The next generation: Three emerging leaders, three ideas”, together with Charlie O'Mulloy, chair of ITFA’s Emerging Leader Committee and Associate Banker at EBRD, at ITFA’s 52nd Annual International Trade and Forfaiting Conference in Split, Croatia on September 9. The Q&A will follow the presentations made by the finalists of the 2026 ITFA Emerging Leader
Hiring a new employee is typically a moment of optimism—and sometimes, the relationship really does go wonderfully for its entire length and ultimately ends on good terms. But when that hope is treated as an assumption, companies make themselves vulnerable. If a client-facing employee does not have a non-solicitation agreement, a business’s customers could be poached. A new employee, hired because of their great industry relationships, might actually have an
Geoffrey Wynne will participate in a panel discussion at ITFA's 52nd Annual International Trade and Forfaiting Conference alongside Ailsa McNeil, Director at Texel, and Hernan Mayol, Board Member and Representative of ITFA Americas and Chair of ITFA’s Latin America Regional Committee (LARC). The session, titled “Financing the future: From defence to critical raw materials,” will be moderated by Clarissa Dann, Editorial Director at Deutsche Bank AG. The session will explore how trade
The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable. This alert
Sullivan & Worcester was featured in Law360 Real Estate Authority's "NYC Real Estate Week In Review," which highlighted the largest New York City real estate transactions recorded during the week. The publication recognized Sullivan's representation of Fattal Hotel Group in its acquisition of the Blakely Hotel, a Manhattan hospitality property located at 136 West 55th Street. The approximately $38.5 million transaction was among the week's largest deals to hit public records.
Molly Depew will present “Basics of Estate and Trust Administration” at the American Bar Association (ABA)’s Skills Training for Estate Planners, a virtual conference taking place September 17–18 and sponsored by the ABA Real Property, Trust & Estate Law Section. The program offers a streamlined, practice-focused introduction to estate planning for attorneys building skills in trusts and estates. Ideal for young lawyers and those transitioning into the field, the course provides
Ryan Rosenblatt was quoted in Law360's article, "Upon Review: The 2026 World Cup's Biggest Legal Stories," which examines the legal, regulatory and policy disputes that emerged during the 2026 World Cup, including issues involving FIFA's disciplinary decisions, immigration challenges, public art protections and the legal dispute surrounding Gillette Stadium's hosting of World Cup matches. Discussing the agreement reached between FIFA's affiliate Boston 2026 and the Town of Foxborough over security fees
On July 16, 2026, the Securities and Exchange Commission (“SEC”) proposed a new rule, Regulation E-Delivery, that would expand the ability of issuers, including registered investment companies, investment advisers, and broker-dealers, to use electronic delivery (“e-delivery”) to satisfy information delivery requirements under the federal securities law. If adopted as proposed, Regulation E-Delivery would broadly address the e-delivery of “covered information” by “covered entities” to “covered recipients” (each as described further
The U.S. Securities and Exchange Commission (“SEC”) announced on July 7, 2026, the creation of the Retail Fraud Working Group, a new initiative within the Division of Enforcement designed to identify and combat fraud targeting main street investors. The announcement formalizes a priority that SEC Enforcement Director David Woodcock previewed in his May 13, 2026, remarks to the Managed Funds Association Legal & Compliance Conference, reflecting the current Commission’s broader
Sullivan & Worcester represented Fattal Hotel Group, owner and operator of 329 hotels across 22 countries and based in Tel Aviv, in its acquisition and financing of The Blakely Hotel in Midtown Manhattan. The acquisition marks the client's first hotel investment in the United States and is a milestone in its evolution from a leading European hospitality operator into a global hotel group. The acquisition was completed on July 7,
Simon Cook, in his role as ITFA's Head of Education, will jointly moderate a Q&A on “The next generation: Three emerging leaders, three ideas”, together with Charlie O'Mulloy, chair of ITFA’s Emerging Leader Committee and Associate Banker at EBRD, at ITFA’s 52nd Annual International Trade and Forfaiting Conference in Split, Croatia on September 9. The Q&A will follow the presentations made by the finalists of the 2026 ITFA Emerging Leader
Hiring a new employee is typically a moment of optimism—and sometimes, the relationship really does go wonderfully for its entire length and ultimately ends on good terms. But when that hope is treated as an assumption, companies make themselves vulnerable. If a client-facing employee does not have a non-solicitation agreement, a business’s customers could be poached. A new employee, hired because of their great industry relationships, might actually have an
Geoffrey Wynne will participate in a panel discussion at ITFA's 52nd Annual International Trade and Forfaiting Conference alongside Ailsa McNeil, Director at Texel, and Hernan Mayol, Board Member and Representative of ITFA Americas and Chair of ITFA’s Latin America Regional Committee (LARC). The session, titled “Financing the future: From defence to critical raw materials,” will be moderated by Clarissa Dann, Editorial Director at Deutsche Bank AG. The session will explore how trade
The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable. This alert
