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Trump Administration Directs CFIUS to Tighten Restrictions on Investment From Certain Countries While Easing National Security...

On 21 February 2025, President Donald J. Trump signaled his administration’s approach to foreign investment policy with a presidential memorandum, “America First Investment Policy” (The Policy). Among the most significant...more

US Treasury Department Moves Closer to Implementing Outbound Investment Restrictions Through Latest Proposed Regulations

On 21 June 2024, the Office of Investment Security of the US Department of the Treasury (Treasury) issued proposed regulations to implement President Biden’s August 2023 Executive Order on Addressing United States Investments...more

The Committee on Foreign Investment in the United States Sharpens Its Enforcement Edge: Proposed Regulatory Revisions Expand...

On 15 April 2024, the Treasury Department’s Office of Investment Security published a Proposed Rule to revise the regulations governing the Committee on Foreign Investment in the United States (CFIUS or the Committee). The...more

United States Imposes Unprecedented Outbound Investment Controls Focused on China

On 9 August 2023, President Biden issued a long anticipated executive order imposing certain limitations, reporting requirements, and prohibitions on outbound investment from the United States into certain sensitive industry...more

CFIUS Proposal Underscores Risks in Foreign Real Estate Acquisitions in the United States

The Committee on Foreign Investment in the United States (CFIUS or the Committee) recently proposed expanding the scope of its jurisdiction to review real estate transactions to add over 200,000 square miles of land...more

Russia-Related Export Controls Continue to Escalate

In a set of actions in coordination with G7 allies, US and UK export control authorities recently announced significant escalations of sanctions and export controls against Russia and Belarus. These actions indicate continued...more

Recent Actions By CFIUS Underscore Importance of Review Process

Earlier this month, the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) took two noteworthy actions that underscore the Committee’s powerful role in reviewing foreign direct investment and...more

Treasury Issues Final Regulations Revamping CFIUS Authority

On January 13, 2020, the U.S. Department of the Treasury (“Treasury”) published two final rules (“Final Rules,” found here and here) that implement most of the remaining provisions of the Foreign Investment Risk Review...more

Treasury Proposes Regulations Implementing Nearly All of FIRRMA’s Provisions

On September 24, 2019, the U.S. Department of the Treasury (“Treasury”) published two proposed rules (together, the “Proposed Rules”) to implement the remaining provisions of the Foreign Investment Risk Review Modernization...more

U.S. International Trade and Investment Security Reviews: The Latest Developments

OVERVIEW - - Oversight of Foreign Investment & Tech Transfer - CFIUS Reforms – FIRRMA - Investment Strategies FOREIGN INVESTMENT & TECH OVERSIGHT - - The Committee on Foreign Investment in the United States...more

Prominent Divestiture Orders Demonstrate CFIUS’s Focus on Access to Sensitive Personal Data as a National Security Concern

Two major actions by the Committee on Foreign Investment in the United States (“CFIUS”) have recently come to light that underscore the significant risks of investments in U.S. businesses that have large volumes of sensitive...more

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