On August 7, 2025, the Treasury Department, as the lead agency of the Committee on Foreign Investment in the United States (CFIUS), released a public version of its 2024 Annual Report to Congress regarding foreign direct investment in the United States. The report highlights key indicators of the CFIUS process and provides statistics on transactions that were filed in 2024 and reflects that CFIUS “continues to process a high volume of transactions, identify transactions that were not submitted to CFIUS that may raise national security considerations, and employ mitigation, monitoring, and enforcement tools to protect national security interests.”

Key highlights from the 2024 report include the following:

  • There were 209 written notices of transactions and 116 declarations filed with CFIUS in 2024 that CFIUS determined to be covered transactions.
    • The leading countries where foreign acquirers filed full notices were: Canada, China, France, Germany, Israel, Japan, Singapore, and the United Arab Emirates.
    • The leading countries where foreign acquirers filed declarations were: Canada, France, Germany, Japan, the United Arab Emirates, and the United Kingdom.
  • Covered notices fell into the following industry sectors: Finance, Information and Services (53%), Manufacturing (33%), Mining, Utilities, and Construction (7%), and Wholesale/Resale Trade and Transportation (7%).
  • CFIUS reviewed 150 covered transactions involving acquisitions of U.S. critical technology companies.
  • Of the 209 covered notices, CFIUS entered into or imposed mitigation measures as follows:
    • CFIUS concluded action after adopting a mitigation agreement or order to resolve national security concerns with respect to 16 notices.
    • CFIUS adopted mitigation agreements to address residual national security concerns with respect to one notice that was voluntarily withdrawn and abandoned.
    • In letters issued by Treasury granting the withdrawal and abandonment for six notices, conditions were imposed (however these did not involve mitigation agreements).
    • Measures were imposed to mitigate interim risk with respect to one notice filed in 2024.
    • One notice of a covered transaction was rejected by CFIUS.
  • Presidential decisions were issued regarding two transactions for which CFIUS initiated a review in 2024.
  • As of the end of 2024, CFIUS was monitoring 242 mitigation agreements and conditions. Four mitigation agreements and conditions were materially modified in 2024, and 25 were terminated.   During the year, CFIUS conducted 79 site visits and asses four penalties in 2024 for breaches of material provisions in mitigation agreements.
  • CFIUS assessed four penalties in 2024 for breaches of material provisions in mitigation agreements. Additionally, one penalty was assessed for submission of a notice and supplemental information containing material misstatements.
  • Regarding non-notified transaction, CFIUS indicated that it identified and preliminarily considered thousands of potential non-notified transactions. It investigated 98 of these, and formally opened an inquiry into 76 of these transactions and requested a filing for 12 non-notified transactions.

CFIUS also noted two developments that occurred in 2024 that go beyond the data in the annual report:

  • In November 2024, Treasury issued two final rules updating the Committee’s regulations. One rule expands CFIUS jurisdiction over real estate transactions, and the second enhances the Committee’s authority to require the submission of certain information, allows the Committee to set timelines for responding to mitigation proposals, and increases the maximum civil monetary penalties available for violations of the CFIUS statute and regulations (see Thompson Hine Update of November 21, 2024);
  • In August 2024, CFIUS announced its largest penalty issued to date and unveiled its new enforcement webpage with information about how CFIUS approaches compliance and enforcement, as well as an updated list of its penalty actions (see CFIUS Enforcement web page).

For comparison purposes, Thompson Hine’s Update on the CFIUS 2023 Report is available here.