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ARTICLE · 04 MARCH 2025

America First Investment Policy

Holland & Knight
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Presidential Memorandum Spells Out the Administration's Priorities for Inbound and Outbound Foreign Investments

United StatesGovernment, Public Sector
Robert Friedman
Robert Friedman
Antonia Tzinova
Antonia Tzinova
Andrew McAllister
Andrew McAllister
Libby Bloxom
Libby Bloxom
Marina Veljanovska O'Brien
Marina Veljanovska O'Brien
Cynthia Liu
Cynthia Liu
Author LinkedIn connections

Highlights

  • President Donald Trump issued a National Security Presidential Memorandum (NSPM) titled "America First Investment Policy" on Feb. 21, 2025. The NSPM outlined new policies regarding inbound and outbound investment review regimes, suggesting a revamp of the procedures of the Committee on Foreign Investment in the United States (CFIUS) and the recently implemented U.S. outbound investment security program. Though the NSPM does not create or impose any immediate rights or obligations on companies, significant and wide-ranging changes implementing such policies are expected.
  • The NSPM directs the creation of an expedited "fast-track" process to ease investment reviews for allies, while focusing resources to make it harder for foreign adversaries – defined as China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia and the Maduro regime in Venezuela – to gain access to sensitive technologies.

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