Podcast: CFIUS: Recent Regulatory Developments
On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more
A month has passed since the Department of Justice (DOJ) National Security Division’s (NSD) issued its Final Rule prohibiting certain transactions involving US government data and Americans’ bulk sensitive personal data....more
On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...more
What's Changed? The U.S. Department of Justice (DOJ) published a Data Security Program (DSP), pursuant to a final rule (Final Rule), which became effective on April 8, 2025....more
On April 11, 2025, the Department of Justice (DOJ) issued guidance (Guidance) to assist individuals and entities in coming into compliance with its final rule, referred to as the "Data Security Program" (DSP Rule), which...more
Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding. The DSP framework is new, comprehensive and raises significant risks and requires careful design and...more
On April 8, the Department of Justice’s (“DOJ’s”) final rule on Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (the “Rule”) formally took effect. ...more
On January 8, 2025, the U.S. Department of Justice (“DOJ”) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by...more
Pursuant to President Biden’s March Executive Order, the DOJ has proposed new rules limiting the transfer of certain categories of data to “countries of concern” or “covered persons”....more
On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more
In a sweeping, coordinated effort across federal agencies, the US government has taken a giant leap forward to prevent access to data that could be exploited to the detriment of national security. On February 28, 2024,...more
The Committee on Foreign Investment in the United States (CFIUS) is a U.S. government interagency committee with the responsibility to review foreign investments in U.S. businesses and real estate transactions for national...more
Pilot Program Mandatory Filing Requirement – Private Investment Fund Considerations - The potential for national security review of foreign investment in the U.S. has been around for 30 years since the 1988 enactment of...more
CFIUS will continue to have broad jurisdiction to conduct national security reviews of foreign investments that could result in foreign control of a U.S. business. When regulations implementing FIRRMA become effective within...more
On January 20, 2017, businessman Donald J. Trump was sworn in as the 45th President of the United States following a contentious and unconventional 2016 presidential election. Republicans also successfully maintained control...more