October 15, 2018 - Regulatory

New CFIUS Pilot Program Expands U.S. Government Review of Tech Transactions

The Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”), which became law on August 13, 2018, effected sweeping change to the authority and processes of the Committee on Foreign Investment in the United States (“CFIUS”). Many of FIRRMA’s most significant changes were not effective immediately, however, as they are subject to rulemaking by the Department of the Treasury. If there were any questions whether Treasury would let the regulatory process initiated by FIRRMA linger, those questions were just answered with the release of unprecedented new CFIUS regulations that include possible multi-billion dollar fines across almost 30 critical technology-related industries, and provisions that make filing certain notifications with CFIUS mandatory. 

Read our client alert.