# CFIUS

> Source: https://aiwiki.ai/wiki/cfius
> Updated: 2026-07-24
> Fact-checked: 2026-07-24
> Categories: AI Hardware, AI Policy & Regulation, Artificial Intelligence
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> Cite as: AI Wiki. "CFIUS." aiwiki.ai, 24 Jul 2026. https://aiwiki.ai/wiki/cfius
> From AI Wiki (https://aiwiki.ai), the free encyclopedia of artificial intelligence. Reuse freely with attribution.

The Committee on Foreign Investment in the United States (CFIUS) is an interagency committee of the US government that reviews foreign investment in American businesses and real estate for national security risk. It operates under section 721 of the Defense Production Act of 1950, codified at 50 U.S.C. 4565, is chaired by the Secretary of the Treasury, and can clear a deal, impose conditions on it, or recommend that the President suspend or prohibit it [1][2]. The President's power extends to completed transactions, which means CFIUS can force an investor to sell something it already owns.

For the [artificial intelligence](https://aiwiki.ai/wiki/artificial_intelligence) industry, CFIUS is one half of a pair of controls on cross-border technology flows. [Export controls](https://aiwiki.ai/wiki/export_controls) and the [Entity List](https://aiwiki.ai/wiki/entity_list) govern what technology may leave the country and to whom; CFIUS governs who may buy the companies that produce it. Since 2017 the committee's most visible actions have clustered in exactly the areas the AI industry depends on: semiconductor design and manufacturing, chip startups, large consumer datasets, and the physical sites where compute is installed.

Since 2 January 2025 the Treasury office that staffs CFIUS has also run a mirror-image program pointed the other way. The Outbound Investment Security Program restricts US money flowing into Chinese AI, semiconductor, and [quantum computing](https://aiwiki.ai/wiki/quantum_computing) firms, and it writes model training compute thresholds directly into binding regulation [4].

## Statutory basis and membership

CFIUS began as an executive-branch committee and gained teeth with the Exon-Florio amendment of 1988, which gave the President authority to block acquisitions on national security grounds. The Foreign Investment and National Security Act of 2007 put the committee itself on a statutory footing after the political fight over Dubai Ports World, and the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) produced the largest expansion of its jurisdiction to date [2].

The committee has nine voting members: the Secretaries of the Treasury, State, Defense, Homeland Security, Commerce, and Energy, the Attorney General, the US Trade Representative, and the Director of the Office of Science and Technology Policy. The Secretary of Labor and the Director of National Intelligence participate as non-voting ex officio members [2].

The statute constrains the President rather than the committee. Before suspending or prohibiting a transaction the President must find credible evidence that the foreign person might take action that threatens to impair national security, and must conclude that other laws do not provide adequate authority to address the risk. Those findings are not subject to judicial review, and civil challenges arising from CFIUS action may be brought only in the US Court of Appeals for the District of Columbia Circuit [1].

## What FIRRMA changed

FIRRMA was enacted on 13 August 2018 as Subtitle A of Title XVII of Public Law 115-232, 132 Stat. 2173 [3]. Before it, CFIUS jurisdiction essentially tracked control: a foreign person acquiring control of a US business. FIRRMA added categories that matter far more to venture-stage technology investing.

The first is the covered investment. A non-controlling stake in a US business that deals in critical technologies, critical infrastructure, or sensitive personal data (the three together are known as TID US businesses) falls within CFIUS jurisdiction if it gives the foreign investor board membership, board observer rights, access to material non-public technical information, or substantive involvement in decisions about the sensitive assets [3]. A minority position in an AI chip startup with an observer seat is therefore reviewable even though the investor controls nothing.

The second is real estate. FIRRMA extended jurisdiction to purchases and leases of land near specified military installations and ports, independent of whether any operating business changes hands [2][3].

The third is mandatory filing. CFIUS had always been a voluntary system in form, and remains so for most deals, but FIRRMA created two classes of transaction where a filing is compulsory: acquisitions of a substantial interest in a TID US business by a foreign person in which a foreign government holds a substantial interest, and certain critical technology transactions [5]. A pilot program that took effect on 10 November 2018 initially defined the second class by a list of NAICS-coded industries in an annex [6]. Treasury replaced that industry test in 2020 with an export-control test: a declaration is mandatory when the US business produces critical technologies for which a US regulatory authorization would be required to export to the foreign investor, assessed without giving effect to license exceptions [5]. That test wires CFIUS directly to the export control system, because "critical technologies" is itself defined by reference to the US Munitions List, the Commerce Control List, nuclear and select agent rules, and emerging and foundational technologies controlled under section 1758 of the Export Control Reform Act of 2018 [7]. Because the test keys off those control lists, every expansion of export controls on advanced [AI accelerators](https://aiwiki.ai/wiki/ai_chip) also enlarges the set of chip and AI deals that must be filed with CFIUS [5][7].

The main FIRRMA regulations took effect on 13 February 2020 [3].

## How a review works

Parties choose between two filing routes. A declaration is a short filing, and CFIUS has 30 days to respond; it may clear the deal, request a full notice, or take no action, which leaves the parties without a safe harbor. A written notice starts a 45-day review, which CFIUS may extend into a 45-day investigation, with one further 15-day extension available in extraordinary circumstances. If the committee refers the matter, the President has 15 days to act [1][2].

Most risk is resolved through mitigation rather than prohibition. CFIUS negotiates agreements that can require anything from US-citizen-only access to specified systems, to divestment of a particular business line, to third-party monitors and audit rights [2]. The committee also runs a non-notified program that identifies transactions nobody filed and invites or compels a filing after the fact, which is how several completed acquisitions have been unwound [2][9].

Enforcement was sharpened in a rule published on 26 November 2024 and effective 26 December 2024. Maximum civil penalties for material misstatements or omissions in a declaration, notice, or response to a CFIUS information request rose to $5 million per violation. For mitigation agreements entered into on or after that date, the maximum penalty is the greatest of $5 million, the value of the person's interest in the US business at the time of the transaction, the value at the time of the violation, or the transaction value. The same rule extended the window to petition for reconsideration of a penalty, setting it at 20 business days from receipt of the penalty notice, and gave the committee 20 business days to respond [8].

Volumes have fallen from their 2022 peak.

| Calendar year | Declarations | Notices | Investigations | Withdrawals |
|---|---|---|---|---|
| 2019 | 94 | 231 | 113 | 30 |
| 2020 | 126 | 187 | 88 | 28 |
| 2021 | 164 | 272 | 130 | 72 |
| 2022 | 154 | 286 | 163 | 87 |
| 2023 | 109 | 233 | 128 | 57 |
| 2024 | 116 | 209 | 116 | 49 |

Source: Congressional Research Service [2].

The 2024 figures amount to 325 covered transactions [2]. Formal mitigation fell sharply that year, to roughly 9 percent of notices from just above 20 percent in 2022 and 2023, while compliance activity rose: 79 site visits against 43 in 2023, 76 formal non-notified inquiries against 60, and four penalties for breaches of mitigation terms. Filings by Chinese investors continued to decline, to 28 from 35 in 2023 and 41 in 2022 [2][9].

## Semiconductor and AI cases

Presidential prohibitions are rare. Semiconductors account for more of them than any other sector.

| Year | US business or asset | Acquirer | Sector |
|---|---|---|---|
| 1990 | MAMCO Manufacturing | CATIC | Aerospace |
| 2012 | Four wind farm companies | Ralls Corporation (Sany Group) | Renewables |
| 2016 | Aixtron SE | Grand Chip Investment | Semiconductor |
| 2017 | Lattice Semiconductor | Canyon Bridge Capital Partners | Semiconductor |
| 2018 | Qualcomm | Broadcom | Semiconductor |
| 2020 | StayNTouch | Beijing Shiji Information Technology | Software |
| 2020 | Musical.ly | ByteDance | Digital platform |
| 2024 | Real property, Cheyenne, Wyoming | MineOne | Crypto mining |
| 2025 | US Steel | Nippon Steel | Steel |
| 2025 | Jupiter Systems | Suirui International | AV equipment |
| 2026 | EMCORE chip assets | HieFo Corporation | Semiconductor |

Source: Congressional Research Service; the Musical.ly and US Steel orders were not ultimately enforced [2].

### Lattice Semiconductor, 2017

Canyon Bridge Capital Partners, a newly formed buyout firm funded by Chinese limited partners, agreed to acquire the Portland, Oregon chipmaker Lattice Semiconductor for $1.3 billion [31]. On 13 September 2017 President [Donald Trump](https://aiwiki.ai/wiki/donald_trump) prohibited the deal and ordered the parties to abandon it within 30 days, extendable by CFIUS up to 90. The order named the full ownership chain, from Canyon Bridge Merger Sub through Yitai Capital Limited to China Venture Capital Fund Corporation Limited [10].

### Qualcomm and Broadcom, 2018

Here CFIUS intervened in the middle of an unsolicited bid, before the target's board had agreed to anything. Acting on a CFIUS interim order, [Qualcomm](https://aiwiki.ai/wiki/qualcomm) postponed its annual stockholders meeting and director election by at least 30 days so the committee could investigate [11]. According to contemporaneous analysis of the committee's 5 March 2018 letter, CFIUS was concerned that [Broadcom](https://aiwiki.ai/wiki/broadcom) would cut Qualcomm's research and development spending, that a weaker Qualcomm would leave an opening for China in 5G standard setting, and that [Huawei](https://aiwiki.ai/wiki/huawei) would be the likely beneficiary [12]. On 12 March 2018 the President prohibited the roughly $117 billion takeover outright, finding credible evidence that Broadcom Limited, a company organized under the laws of Singapore, might take action threatening to impair national security, and ordering the parties to "immediately and permanently abandon the proposed takeover" [13]. Broadcom completed a redomiciliation from Singapore to Delaware three weeks later, on 4 April 2018 [14].

### MoneyGram and Ant Financial, 2018

[Ant Group](https://aiwiki.ai/wiki/ant_group), then Ant Financial, agreed to buy the money transfer firm MoneyGram in a deal that would have given a Chinese payments company a large US remittance network and its customer records. The parties terminated the merger on 2 January 2018, with chief executive Alex Holmes stating that "it has now become clear that CFIUS will not approve this merger." Ant paid MoneyGram a $30 million termination fee [15]. No presidential order was needed; the committee's refusal to clear the deal was sufficient.

### Grindr and Kunlun, 2019-2020

The Chinese firm Kunlun acquired the dating app Grindr without filing with CFIUS. In late March 2019 it emerged that the committee had informed Kunlun that its continued ownership was a national security risk and had required divestiture [16], and the firm subsequently divested itself of Grindr [31]. The case established that a completed, unfiled acquisition of a business holding sensitive personal data on US users could be unwound years later.

### TikTok and ByteDance, 2020 onward

CFIUS reviewed [ByteDance](https://aiwiki.ai/wiki/bytedance)'s 2017 purchase of Musical.ly retroactively. On 14 August 2020 the President ordered ByteDance to divest all assets used to support [TikTok](https://aiwiki.ai/wiki/tiktok) in the United States within 90 days, and to certify to CFIUS that it had destroyed all US user data derived from the TikTok and Musical.ly apps [17]. That order was never enforced; the dispute moved to separate legislation, and in Executive Order 14352 of 25 September 2025 the President determined that a restructuring into a US-based joint venture in which ByteDance and its affiliates hold less than 20 percent qualified as a divestiture under the Protecting Americans from Foreign Adversary Controlled Applications Act. CFIUS was assigned a continuing role, executing an agreement with certain investors to align their economic interests with compliance [18].

### MineOne, 2024

President [Joe Biden](https://aiwiki.ai/wiki/joe_biden) ordered a Chinese-majority-owned entity to divest 12.06 acres at 635 Logistics Drive in Cheyenne, Wyoming, within 120 days, and to remove its cryptocurrency mining equipment within 90. The site sits within one mile of Francis E. Warren Air Force Base, and the order cited specialized foreign-sourced equipment potentially capable of facilitating surveillance [19]. The case is a template for how CFIUS treats foreign-owned [data center](https://aiwiki.ai/wiki/data_center) sites near sensitive facilities, a question that scales with AI buildouts.

### EMCORE and HieFo, 2026

On 2 January 2026 the President prohibited HieFo Corporation, a Delaware company controlled by a citizen of the People's Republic of China, from holding the digital chips and related wafer design, fabrication, and processing businesses it had acquired from EMCORE Corporation on 30 April 2024, and gave it 180 days to divest [20]. It is the most recent presidential CFIUS order in the Congressional Research Service tally published in April 2026 [2].

### Rain AI and Prosperity7

Bloomberg reported in December 2023 that CFIUS had required Prosperity7 Ventures, a fund backed by Saudi Aramco, to sell its stake in [Rain AI](https://aiwiki.ai/wiki/rain_ai), a [neuromorphic](https://aiwiki.ai/wiki/neuromorphic_computing) chip startup whose backers included [Sam Altman](https://aiwiki.ai/wiki/sam_altman); Prosperity7 had led a $25 million round in 2022. Treasury declined to comment, noting that "CFIUS does not publicly comment on transactions that it may or may not be reviewing" [21]. If accurate, it is the clearest public example of CFIUS acting on a venture-stage AI hardware investment, and by a Gulf rather than Chinese investor.

## Executive Order 14083 and the AI factor list

Executive Order 14083, signed 15 September 2022, is the first presidential instruction telling CFIUS what to weigh in technology cases. It directs the committee to consider whether a transaction involves manufacturing capabilities, services, critical mineral resources, or technologies fundamental to US technological leadership, "such as microelectronics, artificial intelligence, biotechnology and biomanufacturing, quantum computing, advanced clean energy, and climate adaptation technologies." It also directs attention to supply chain resilience, to investments by foreign persons with the capability and intent to conduct malicious cyber-enabled activity, and to transactions giving access to US persons' health, digital identity, or other biological data [22].

## The outbound program

Executive Order 14105, signed 9 August 2023, declared a national emergency over the advancement by countries of concern in sensitive technologies and directed Treasury to build a program covering semiconductors and microelectronics, quantum information technologies, and artificial intelligence. The order created two tiers, prohibited transactions and notifiable transactions, and left the boundaries to rulemaking [23]. Treasury's final rule was published on 15 November 2024 at 89 FR 90398 and took effect on 2 January 2025 as 31 CFR part 850. The countries of concern are the People's Republic of China, Hong Kong, and Macau. A notification must be filed no later than 30 days after a covered transaction is completed, or after the US person acquires actual knowledge that would have made it a covered transaction [4].

The AI provisions make model training compute a legal trigger.

| Tier | AI activity by the covered foreign person | Threshold |
|---|---|---|
| Prohibited | Developing an AI system designed exclusively for, or intended for, military, government intelligence, or mass-surveillance end use | No compute threshold |
| Prohibited | Training any AI system above a compute ceiling | Greater than 10^25 computational operations, or 10^24 when trained primarily on biological sequence data |
| Notifiable | Developing an AI system, not already prohibited, designed or intended for military, government intelligence, or mass-surveillance end use, or for cybersecurity applications, digital forensics tools, penetration testing tools, or the control of robotic systems | No compute threshold |
| Notifiable | Training any AI system above a lower compute floor | Greater than 10^23 computational operations |

Sources: 31 CFR 850.224 and 850.217 [24][25]. Both sections carry a note that a person customizing, configuring, or fine-tuning a third-party model strictly for its own internal, non-commercial use does not thereby trigger the rule, unless that internal use is for military, government intelligence, or mass-surveillance end use, or for digital forensics tools, penetration testing tools, or the control of robotic systems [24][25].

The national emergency underlying the program has been continued annually, most recently by a notice signed 6 August 2025 that extends it through 9 August 2026 [32]. Congress then codified the regime. The Comprehensive Outbound Investment National Security Act became law on 18 December 2025 as Title LXXXV of the fiscal 2026 National Defense Authorization Act, Public Law 119-60. It adds hypersonic systems and high-performance computing and supercomputing to the covered sectors, extends the framework to a broader set of transaction types including greenfield investments and joint ventures, and gives Treasury 450 days to issue implementing regulations. The existing part 850 rules remain in force in the meantime [26][27].

## Policy direction and criticism

The America First Investment Policy memorandum of 21 February 2025 set out the current administration's two-track approach. On restriction, it directs the use of "all necessary legal instruments, including the Committee on Foreign Investment in the United States (CFIUS), to restrict PRC-affiliated persons from investing in United States technology, critical infrastructure, healthcare, agriculture, energy, raw materials, or other strategic sectors," and says the administration will seek to strengthen CFIUS authority over greenfield investments and "to restrict foreign adversary access to United States talent and operations in sensitive technologies (especially artificial intelligence)." On facilitation, it calls for an expedited fast-track process for allied and partner investors and for an end to "overly bureaucratic, complex, and open-ended 'mitigation' agreements" in favor of concrete actions completable within a fixed time [28].

Treasury announced the fast-track pilot in May 2025, built around a Known Investor portal through which pre-vetted investors submit information ahead of a filing. The pilot began with a small invited group and Treasury has published few operational details; practitioners expect eligibility to turn on demonstrable distance and independence from governments or entities deemed a national security risk, on a strong record of adherence to prior CFIUS national security agreements, and on a documented compliance culture [29]. In February 2026 Treasury issued a request for information on the program, asking about eligibility criteria, governance and personnel practices, compliance history, and broader process efficiencies, with comments due 18 March 2026. The notice cautions that "participation in the Known Investor Program alone would not guarantee a particular outcome" [30].

Practitioners and analysts point to several persistent limits. CFIUS has no jurisdiction over greenfield investment, so a foreign company that builds a new US facility from scratch, including a data center, generally falls outside the regime unless it acquires a US business or covered real estate; the 2025 memorandum acknowledges the gap and says the administration will seek, in consultation with Congress, to strengthen CFIUS authority over greenfield investments [28]. The process is opaque by design, since the committee does not confirm or deny reviews and presidential orders state conclusions rather than reasoning, which leaves parties and the public to reconstruct rationales from litigation and press reporting. And the compute thresholds in the outbound rule are fixed numbers applied to a moving target: the notification floor sits at 10^23 computational operations, so as training runs get larger an unchanged floor sweeps in progressively more ordinary work [25].

## See also

- [Export controls](https://aiwiki.ai/wiki/export_controls)
- [Entity List](https://aiwiki.ai/wiki/entity_list)
- [CHIPS Act](https://aiwiki.ai/wiki/chips_act)
- [Ant Group](https://aiwiki.ai/wiki/ant_group)
- [Compute governance](https://aiwiki.ai/wiki/compute_governance)
- [AI regulation](https://aiwiki.ai/wiki/ai_regulation)

## References

1. 50 U.S.C. 4565, "Authority to review certain mergers, acquisitions, and takeovers." Cornell Legal Information Institute. https://www.law.cornell.edu/uscode/text/50/4565
2. Congressional Research Service, "CFIUS: An Overview," IF10177, 28 April 2026. https://www.everycrsreport.com/reports/IF10177.html
3. US Department of the Treasury, "Provisions Pertaining to Certain Investments in the United States by Foreign Persons," final rule, 85 FR 3112, 17 January 2020. https://www.govinfo.gov/content/pkg/FR-2020-01-17/html/2020-00188.htm
4. US Department of the Treasury, "Provisions Pertaining to U.S. Investments in Certain National Security Technologies and Products in Countries of Concern," final rule, 89 FR 90398, 15 November 2024. https://www.govinfo.gov/content/pkg/FR-2024-11-15/html/2024-25422.htm
5. 31 CFR 800.401, "Mandatory declarations." Cornell Legal Information Institute. https://www.law.cornell.edu/cfr/text/31/800.401
6. US Department of the Treasury, "Determination and Temporary Provisions Pertaining to a Pilot Program To Review Certain Transactions Involving Foreign Persons and Critical Technologies," 83 FR 51322, 11 October 2018. https://www.govinfo.gov/content/pkg/FR-2018-10-11/html/2018-22182.htm
7. 31 CFR 800.215, "Critical technologies." Cornell Legal Information Institute. https://www.law.cornell.edu/cfr/text/31/800.215
8. US Department of the Treasury, "Penalty Provisions, Provision of Information, Negotiation of Mitigation Agreements, and Other Procedures Pertaining to Certain Investments in the United States by Foreign Persons and Certain Transactions by Foreign Persons Involving Real Estate in the United States," final rule, 89 FR 93179, 26 November 2024. https://www.govinfo.gov/content/pkg/FR-2024-11-26/html/2024-27310.htm
9. Covington & Burling LLP, "Overview and Key Takeaways from CFIUS 2024 Annual Report," August 2025. https://www.cov.com/en/news-and-insights/insights/2025/08/overview-and-key-takeaways-from-cfius-2024-annual-report
10. "Regarding the Proposed Acquisition of Lattice Semiconductor Corporation by China Venture Capital Fund Corporation Limited," 82 FR 43665, 18 September 2017. https://www.govinfo.gov/content/pkg/FR-2017-09-18/html/2017-20005.htm
11. Qualcomm, "Qualcomm Responds to Broadcom Statement," 5 March 2018. https://investor.qualcomm.com/news-events/press-releases/news-details/2018/Qualcomm-Responds-to-Broadcom-Statement-03-05-2018/
12. Dechert LLP, "Trump Administration Blocks Broadcom's Attempted Takeover of Qualcomm," March 2018. https://www.dechert.com/knowledge/onpoint/2018/3/trump-administration-blocks-broadcoms-attempted-takeover-of-qual.html
13. "Regarding the Proposed Takeover of Qualcomm Incorporated by Broadcom Limited," 83 FR 11631, 15 March 2018. https://www.govinfo.gov/content/pkg/FR-2018-03-15/html/2018-05479.htm
14. Broadcom, "Broadcom Completes Redomiciliation to the United States," PR Newswire, 4 April 2018. https://www.prnewswire.com/news-releases/broadcom-completes-redomiciliation-to-the-united-states-300624646.html
15. MoneyGram and Ant Financial, "MoneyGram and Ant Financial Announce Termination of Amended Merger Agreement," PR Newswire, 2 January 2018. https://www.prnewswire.com/news-releases/moneygram-and-ant-financial-announce-termination-of-amended-merger-agreement-300576618.html
16. Cleary Gottlieb, "CFIUS Forces Kunlun to Unwind 2016 Acquisition of Grindr," April 2019. https://www.clearygottlieb.com/news-and-insights/publication-listing/cfius-forces-kunlun-to-unwind-2016-acquisition-of-grindr
17. "Regarding the Acquisition of Musical.ly by ByteDance Ltd.," 85 FR 51297, 19 August 2020. https://www.govinfo.gov/content/pkg/FR-2020-08-19/html/2020-18360.htm
18. Executive Order 14352, "Saving TikTok While Protecting National Security," 90 FR 47219, 30 September 2025. https://www.govinfo.gov/content/pkg/FR-2025-09-30/html/2025-19139.htm
19. "Regarding the Acquisition of Certain Real Property of Cheyenne Leads by MineOne Cloud Computing Investment I L.P.," 89 FR 43301, 16 May 2024. https://www.govinfo.gov/content/pkg/FR-2024-05-16/html/2024-10966.htm
20. "Regarding the Acquisition of Certain Assets of EMCORE Corporation by HieFo Corporation," 91 FR 895, 8 January 2026. https://www.govinfo.gov/content/pkg/FR-2026-01-08/html/2026-00248.htm
21. "US compels Saudi fund to exit Altman-backed AI chip startup," Bloomberg reporting via Yahoo, 1 December 2023. https://tech.yahoo.com/ai/articles/us-compels-saudi-fund-exit-235332541.html
22. Executive Order 14083, "Ensuring Robust Consideration of Evolving National Security Risks by the Committee on Foreign Investment in the United States," 87 FR 57369, 20 September 2022. https://www.govinfo.gov/content/pkg/FR-2022-09-20/html/2022-20450.htm
23. Executive Order 14105, "Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern," 88 FR 54867, 11 August 2023. https://www.govinfo.gov/content/pkg/FR-2023-08-11/html/2023-17449.htm
24. 31 CFR 850.224, "Prohibited transaction." Cornell Legal Information Institute. https://www.law.cornell.edu/cfr/text/31/850.224
25. 31 CFR 850.217, "Notifiable transaction." Cornell Legal Information Institute. https://www.law.cornell.edu/cfr/text/31/850.217
26. Baker McKenzie, "President Trump Signs COINS Act Codifying and Expanding Outbound Investment Regulations," 18 December 2025. https://sanctionsnews.bakermckenzie.com/president-trump-signs-coins-act-codifying-and-expanding-outbound-investment-regulations/
27. Covington & Burling LLP, "FY26 NDAA Outbound Investment Provisions Overview," December 2025. https://www.cov.com/en/news-and-insights/insights/2025/12/fy26-ndaa-outbound-investment-provisions-overview
28. The White House, "America First Investment Policy," presidential memorandum, 21 February 2025. https://www.whitehouse.gov/presidential-actions/2025/02/america-first-investment-policy/
29. Baker Botts, "Preparing for the CFIUS Fast Track Program," July 2025. https://www.bakerbotts.com/thought-leadership/publications/2025/july/preparing-for-the-cfius-fast-track-program
30. US Department of the Treasury, "Request for Information Pertaining to the CFIUS Known Investor Program and Streamlining the Foreign Investment Review Process," 91 FR 5694, 9 February 2026. https://www.govinfo.gov/content/pkg/FR-2026-02-09/html/2026-02481.htm
31. Congressional Research Service, "The Committee on Foreign Investment in the United States (CFIUS)," RL33388, 26 February 2020. https://www.everycrsreport.com/reports/RL33388.html
32. "Continuation of the National Emergency With Respect to the Advancement by Countries of Concern in Sensitive Technologies and Products Critical for the Military, Intelligence, Surveillance, or Cyber-Enabled Capabilities of Such Countries," 90 FR 38601, 8 August 2025. https://www.govinfo.gov/content/pkg/FR-2025-08-08/html/2025-15194.htm

