Final Regulations Implement FIRRMA – Cooley M&A


The US Department of the Treasury has issued two final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018. The final regulations broadly expand the jurisdiction of the Committee on Foreign Investment in the United States to review foreign investment transactions that implicate US national security concerns and to mitigate such concerns.

This article provides an overview of the Committee and its authority, discusses key aspects of the final regulations and addresses questions that the business and investment communities will face as they consider whether future investments may be subject to CFIUS jurisdiction and the requirement to submit mandatory CFIUS filings in certain circumstances.

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Contributors

Erin Estevez

Christopher Kimball

Kevin King

Dillon Martinson

Sarah Oliai

Rebecca Ross

Patrick M. Stewart

Karen Tsai



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