On June 9, the President issued an Executive Order on Protecting Americans’ Sensitive Data from Foreign Adversaries (EO 14034), rescinding three executive orders issued in the previous administration that prohibited transactions with the mobile applications TikTok and WeChat and eight other Chinese-developed and -controlled applications.  At the same time, the EO makes clear that the current administration remains focused on protecting the information and communications technology and services (ICTS) supply chain against threats from foreign adversaries, defined to include China, as set forth in the May 2019 Executive Order 13873 (Securing the Information and Communications Technology and Services Supply Chain) and its implementing regulations.  The EO also identifies criteria for the Department of Commerce to use in evaluating the risks of a connected software application.

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Photo of Caroline Brown Caroline Brown

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.