ARTICLE · 26 NOVEMBER 2024

A Stronger CFIUS: Final Rules Issued Expanding Mitigation And Enforcement Powers

Venable LLP

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On November 18, 2024, the U.S. Department of the Treasury issued a final rule enhancing the mitigation monitoring and enforcement tools of the Committee on Foreign Investment in the United States (CFIUS or the "Committee").

United StatesGovernment, Public Sector

Maria J.K. Stosz

On November 18, 2024, the U.S. Department of the Treasury issued a final rule enhancing the mitigation monitoring and enforcement tools of the Committee on Foreign Investment in the United States (CFIUS or the "Committee"). As we noted this past spring, this represents the first major update to CFIUS's enforcement powers since Congress substantially expanded the Committee's jurisdiction through enactment of the Foreign Investment Risk Review Modernization Act (FIRRMA) in 2018.

There were only limited changes between the newly released final rules and the rules as proposed last spring. As described in more detail in our prior alert, the new rules establish higher maximum civil penalties for noncompliance, including noncompliance with CFIUS-imposed mitigation agreements, increasing the maximum penalty 20 times over, from $250,000 to $5 million in most cases.

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