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White House Releases “America First Investment Policy” Memo Outlining President Trump’s Approach to Foreign Investment

On February 21, President Trump issued the “America First Investment Policy” National Security Presidential Memorandum (“NSPM”) which outlines the Administration’s approach to foreign investment in the United States. The NSPM...more

Impact of Government Shutdown on US Antitrust Merger Enforcement and CFIUS Reviews - December 2024

The US federal government is at risk of a shutdown unless Congress can enact appropriations to fund certain federal operations by December 20, 2024. In September 2023, the Department of Justice (DOJ) issued plans for how a...more

CFIUS Regulatory Expansion: Five Things You Need to Know

The U.S. Department of the Treasury ("Treasury") has engaged in a flurry of rulemaking over the last year, most recently issuing a final rule to sharpen and enhance the Committee on Foreign Investment in the United States...more

The FCC Proposes New Submarine Cable Systems Rules: Six Key Facts to Know

For the first time since 2001, in an unanimous vote, the Federal Communications Commission (the "FCC") is proposing a major overhaul of its submarine cable licensing rules in its recently released Notice of Proposed...more

CFIUS Announces Enforcement Updates, Including Details on Large Penalty Assessments

The Committee on Foreign Investment in the United States (CFIUS or the Committee) has launched a new CFIUS Enforcement webpage, highlighting the Committee's heightened focus on "increasingly exercising its enforcement...more

CFIUS 2023 Annual Report Shows Decrease in Filings, Continued Higher Pace of Mitigation, and CFIUS Issuing Penalties for...

The Committee on Foreign Investment in the United States (“CFIUS”) recently published its Annual Report to Congress covering calendar year 2023 (the “Report”). The Report indicates a number of notable trends—some new and...more

CFIUS Proposes Regulatory Updates to Shorten Mitigation Negotiation Timelines for Transaction Parties & Expand CFIUS Authorities...

On April 11th, the US Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM) to "enhance certain CFIUS procedures and sharpen...more

Impact of Government Shutdown on US Antitrust Merger Enforcement and CFIUS Reviews

The US federal government is at risk of a partial shutdown unless Congress can enact appropriations to fund certain federal operations by September 30, 2023. Both the Department of Justice (DOJ) and Federal Trade Commission...more

CFIUS 2022 Annual Report Shows Significant Increase in Imposition of Mitigation Measures and Other Notable Trends

The Committee on Foreign Investment in the United States ("CFIUS" or the "Committee") recently released its Annual Report to Congress for calendar year 2022 (the "Report"). Overall, the Report underscores an increasingly...more

New CFIUS Guidance Negates Use of “Springing Rights” for Mandatory Filings

The Committee on Foreign Investment in the United States (CFIUS) recently issued a new Frequently Asked Question (FAQ) that updates CFIUS's interpretation of the "completion date" for a transaction, which represents a...more

FOCI Update: The Evolving US Department Of Defense FOCI Environment, Process & Timing

The foreign ownership, control or influence ("FOCI") program administered by the Department of Defense's ("DoD") Defense Counterintelligence and Security Agency ("DCSA"), which is by far the largest US FOCI program, continues...more

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