On September 25, 2025, President Donald Trump issued an Executive Order (EO), “Saving TikTok While Protecting National Security”, stating that “a plan has been presented to me to undergo a qualified divestiture of TikTok’s United States operations, as outlined in a framework agreement.” While the agreement has not been made public, the EO indicates that:
FDI/CFIUS
Treasury Releases Annual CFIUS Report
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…
President Trump Orders Unwinding of 2020 Acquisition of U.S. Audio Visual Technology Company by Chinese Company
On July 11, 2025, President Donald Trump issued an Executive Order directing that the February 2020 acquisition of Jupiter Systems, LLC of Delaware, and several of its foreign based subsidiaries (Jupiter), by Suirui International Co., Ltd. (Suirui), a Hong Kong/Chinese company, be unwound. Stating only that there is “credible evidence” Suirui might take action that threatens…
Treasury Announces Intent to Launch a CFIUS Fast Track Pilot Program to Streamline Review
On May 8, 2025, the U.S. Department of the Treasury announced its intent to launch a Fast Track Pilot Program to encourage greater investment in U.S. businesses from allied and partner countries. This initiative will introduce a Known Investor portal, allowing the Committee on Foreign Investment in the United States (CFIUS) to collect information from…
President Trump Orders De Novo CFIUS Review of U.S. Steel Acquisition
On April 7, 2025, President Donald Trump issued a Presidential Memorandum directing the Secretary of the Treasury and others in his administration to conduct a new review of the acquisition of U.S. Steel Corporation by Nippon Steel Corporation “to assist me in determining whether further action in this matter may be appropriate.” Citing former President…
President Trump Issues America First Investment Policy Memorandum Impacting FDI into the U.S. and Outbound Investment to Foreign Adversaries
On February 21, 2025, President Trump issued the America First Investment Policy Memorandum (“Memorandum”). The Memorandum aims to promote foreign direct investment (FDI) from “allies and partners” while restricting inbound investment from and outbound investment to “foreign adversaries,” such as China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and the Nicolás Maduro…
Biden Blocks the Proposed Sale of U.S. Steel to Nippon Steel
On January 3, 2025, President Joseph Biden issued a Presidential Order blocking an approximately $15 billion proposed acquisition by Nippon Steel Corporation (Nippon Steel) of Japan to purchase Pittsburgh-based United States Steel Corporation (U.S. Steel). Explaining that the proposed acquisition might result in actions that threaten to impair the national security of the United States…
CFIUS Issues Final Rule Enhancing Enforcement and Penalty Regulations
On November 18, 2024, the Department of the Treasury (Treasury), as Chair of the interagency Committee on Foreign Investment in the United States (CFIUS), issued a final rule to enhance certain CFIUS procedures and sharpen its penalty and enforcement authorities. It revises certain provisions of the CFIUS regulations, 31 C.F.R. Parts 800 and 802, pertaining…
Final Rule Issued on Outbound U.S. Investments in National Security-Related Technologies in Countries of Concern
The Department of the Treasury has issued a Final Rule to implement Executive Order 14105 of August 9, 2023, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern.” This Final Rule provides the operative regulations and a detailed explanatory discussion regarding the intent and application of these new U.S.
CFIUS Issues Final Rule Expanding Coverage of Real Estate Transactions Near More Than 60 Military Installations
On November 7, 2024, the Committee on Foreign Investment in the United States (CFIUS), in coordination with the Department of Defense (DoD), issued a Final Rule that expanded its ability to review certain real estate transactions by foreign persons near more than 60 military bases and installations across 30 states. In addition, CFIUS’s jurisdiction over…