FEOC Rules and Energy Projects: Risk Allocation, Compliance & Contracting Strategies

Partner Heather Cooper and associate John Zhang led a discussion focusing on how new Foreign Entity of Concern (FEOC) rules are introducing heightened scrutiny and complexity for energy projects, particularly across supply chains and tax incentives. This session discussed key requirements, compliance challenges, and the implications for contracts and project structuring, and offered strategies to help manage regulatory risk and maintain project viability and financing eligibility.