Key Issues For Pending CFIUS Rulemaking

The Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), enacted on August 13, 2018, represented the first major reform in a decade of national security reviews conducted by the Committee on Foreign Investment in the United States (CFIUS). Only certain portions of FIRRMA, have been implemented to date. Although interim regulations were published in October 2018, many of FIRRMA’s key provisions are not yet in effect while others may be subject to the interim rules may be implemente