On September 24, 2019, the U.S. Department of the Treasury (“Treasury”) published proposed regulations for the implementation of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). As directed by FIRRMA, the proposed regulations significantly expand the jurisdictional authority of the Committee on Foreign Investment in the United States (“CFIUS”), but also formally establish meaningful exceptions with the aim of promoting foreign investment in the United States while protecting U.S. national security interests. In addition, the proposed regulations prescribe procedural changes concerning the form and length of CFIUS submissions and reviews.
