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First Quarter Foreign Direct Investment Updates

On February 21, 2025, the Trump administration published its “America First Investment Policy” memorandum. Among other items, the Policy calls for the United States to restrict China-affiliated persons from investing in...more

America First Investment Policy Restricts Adversaries and Welcomes Investment from Allies

On February 21, 2025, President Trump issued a memorandum titled "America First Investment Policy" (the “Policy”), outlining new measures to shape U.S. investment policy. Though the Policy makes it clear that the United...more

U.S. Issues Unprecedented Order Restricting Investment in China

Senator Cornyn made the above statement on the Senate floor on November 14, 2023, while advocating for his colleagues to pass the Outbound Investment Transparency Act as part of the 2024 National Defense Authorization Act...more

The Mergers & Acquisitions Review: US Trade Compliance Due Diligence 2024

In addition to a myriad of issues to consider during M&A transactions, parties should conduct due diligence related to US trade regulations and the often-related foreign investment regulations that arise in the context of an...more

Treasury Finalizes Rule Increasing CFIUS Penalties and Expanding Enforcement Powers

On November 17, 2024, the Department of the Treasury (“Treasury”), in its role as chair of the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”), published a final rule (“Final Rule”)...more

The Corporate Transparency Act: Treasury’s New Back Door for Finding CFIUS Non-Notified Transactions

Much has been written about the Corporate Transparency Act (“CTA”), which was enacted on January 1, 2021, and went into effect on January 1, 2024. Briefly, the CTA requires “reporting companies” to disclose beneficial...more

CFIUS Updates: New FAQs Clarify Positions; Possible Expansion of Scope of Real Estate Review

In our recent article Amid TikTok Tensions, CFIUS Signals Increased Enforcement and Other Updates, we discussed updates from the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) primarily with...more

Amid TikTok Tensions, CFIUS Signals Increased Enforcement and Other Updates

MENU InsightsAmid TikTok Tensions, CFIUS Signals Increased Enforcement and Other UpdatesBy: Derrick Kyle, Senior AssociateDate: 04/25/2023As TikTok CEO Shou Zi Chew was facing (often contentious) questions from members of...more

Congress Contemplates Committee to Review Outbound Investment

On February 4, 2022, the House of Representatives passed the National Critical Capabilities Defense Act of 2021 (“NCCDA”) as part of the much larger America Creating Opportunities for Manufacturing, Pre-Eminence in...more

When CFIUS Mitigation Agreements and FOCI Reviews Overlap: A Critical Balancing Act

On June 9, 2021, Momentus Inc., a U.S. commercial space company offering in-space transportation and infrastructure services, as a condition to its acquisition by a foreign-owned company, entered into a National Security...more

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