FR EA

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Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / cfius-risk-assessment-mitigation-strategy.docx
cfius-risk-assessment-mitigation-strategy.docx · 1032-00004

Parties

HARKNESS LLP
Marlowe Asset Management Photonics Inc
Halcyon US Holdings Inc
Pacific Basin Credit Corp
Ironclad Defense Systems Inc
Halcyon US Inc
Whitmore Compliance Group LLC
Gale LLP

Dates

June 10, 2023
June 5, 2023
June 22, 2023
July 14, 2023
June 19, 2023
February 14, 2009
June 1, 2023
June 15, 2023
July 21, 2023
July 5, 2023

Amounts

$1.42
$1,420,000,000
$85,000,000
$50
$35
$1,505,000,000
$900
$520
€300
$287.4

Obligations

Under NISPOM, foreign ownership, control, or influence ("FOCI") over a cleared entity must be mitigated to a level acceptable to DCSA in order to retain the FCL
The monitor must be formally approved by CFIUS during NSA negotiation
HSAG must retain meaningful board representation and commercial governance authority
Monitor costs must be reasonable and benchmarked against comparable engagements
Government agencies must not have unilateral authority to expand monitor scope (and cost) without consultation
Cybersecurity standards must be consistent with VPI's existing regulatory obligations; no goldplating