ARTICLE · 24 JANUARY 2020

CFIUS Releases Final FIRRMA Regulations

Cleary Gottlieb Steen & Hamilton LLP

Explore more from Cleary Gottlieb Steen & Hamilton LLP

On January 13, 2020, the U.S. Department of the Treasury released final regulations implementing the updates to the foreign investment review process of the Committee on Foreign Investment in the United States ...

United StatesGovernment, Public Sector

John McGill, Jr.

Nathanael F. Kurcab

Hani Isam Bashour

On January 13, 2020, the U.S. Department of the Treasury ("Treasury") released final regulations (the "Final Regulations")¹ implementing the updates to the foreign investment review process of the Committee on Foreign Investment in the United States ("CFIUS") contained in the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA"). The Final Regulations, effective February 13, 2020, largely track the September 2019 proposed regulations (the "Proposed Regulations")² to implement FIRRMA's expansion of CFIUS's jurisdiction. FIRRMA in turn codified existing CFIUS practice as it has evolved in recent years, particularly with respect to a focus on U.S. businesses involving critical technologies, critical infrastructure, and sensitive personal data, and added a limited mandatory filing regime. The Final Regulations continue this incremental path by incorporating revisions to address issues arising from public comments on the Proposed Regulations and the sunset of

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

Department Of State Proposes ITAR Revisions: Top Points

United StatesGovernment, Public Sector

Capital Snapshot: A Monthly Overview Of The Issues, Events, And Timelines Driving Federal Policy Decisions

United StatesGovernment, Public Sector

Arnold & Porter

FDA Seeks To Recruit Scientific Expertise And Consumer Voices To Advisory Committees

United StatesGovernment, Public Sector

2026 State Attorneys General Election Report

United StatesGovernment, Public Sector

Foley & Lardner LLP

Treasury Announces First Civil Penalty Under Outbound Investment Security Program

United StatesGovernment, Public Sector

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Government, Public Sector

SBA Extends Deadline For Comments On Historic Overhaul Of Size Standards

The Small Business Administration has extended the comment period for two proposed rules that could dramatically reshape federal government contracting by significantly expanding the pool of entities eligible for small business set-aside procurements. With some size standard thresholds proposed to increase as much as tenfold, these changes would fundamentally alter the makeup of the small business contractor base.

United StatesGovernment, Public Sector

Crowell & Moring LLP

D.C. Circuit Rules Pentagon Can Exclude Anthropic From Supply Chain

The U.S. Court of Appeals for the D.C. Circuit has ruled that the Department of War can exclude Anthropic from its supply chain under the Federal Acquisition Supply Chain Security Act, finding that the AI company's ability to manipulate its Claude model creates a supply chain risk. This decision contrasts with an earlier California district court ruling that blocked a similar designation under a different statute, creating a complex legal landscape for AI providers and government contractors.

United StatesGovernment, Public Sector

Taft, Stettinius & Hollister LLP

FMCSA MOTUS Implementation – Common Motor Carrier Concerns

The Federal Motor Carrier Safety Administration launched MOTUS in May 2026, replacing legacy registration platforms and fundamentally changing how motor carriers, freight brokers, and surface freight forwarders handle operating authority applications and license maintenance. While designed to combat fraud and streamline registration activities, the transition has created significant user experience challenges that threaten operating authority status and customer relationships for transportation service prov

United StatesGovernment, Public Sector

Benesch, Friedlander, Coplan & Aronoff LLP

When Can Congress Refuse To Seat A Duly-Elected Candidate?

Never. In 1969, the U.S. Supreme Court ruled that the Speaker of the House could not exclude a duly-elected candidate for the U.S. House of Representatives.

United StatesGovernment, Public Sector

Holland & Knight

Sanctions Update: October 19, 2026

This comprehensive sanctions update examines the US delisting of Venezuelan politician Jorge Rodriguez amid diplomatic negotiations and energy sector expansion, while tracking global sanctions developments including new US restrictions on Iranian banks, UK measures targeting hostile Iranian activities, EU designations for sanctions circumvention, and China's proposed export controls on advanced technologies.

GlobalGovernment, Public Sector

BIOSECURE Act Update: Court Enjoins WuXi AppTec’s 1260H Designation, but Strategic and Compliance Clocks Keep Running

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp

United StatesGovernment, Public Sector

Greenberg Traurig

Massachusetts’ 2026 Ballot Questions: What Clients Need To Know

Massachusetts voters will decide nine statewide ballot questions in November 2026 that could fundamentally reshape the state's legal, regulatory, and fiscal landscape. These measures address government transparency, election reforms, housing development, marijuana regulation, firearms laws, and state revenue limits, with implications extending far beyond Election Day to implementation, regulation, and ongoing policy debates.

United StatesGovernment, Public Sector

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Weekly Sanctions Update: October 13, 2026

The US has authorized Russian diesel imports while simultaneously expanding sanctions against the International Criminal Court and Iran's shadow fleet. These developments highlight tensions between energy security concerns and sanctions enforcement, as international partners express divergence over US policy directions.

GlobalGovernment, Public Sector

OFAC Broadens Cuba Sanctions And Restricts Payments And Travel

The U.S. Treasury Department's Office of Foreign Assets Control has implemented sweeping changes to Cuba sanctions, introducing a new regulatory framework that extends restrictions beyond U.S. persons to foreign entities and financial institutions. These measures eliminate key banking authorizations, expand transaction prohibitions to include intermediary payments, and significantly narrow travel permissions, creating new compliance challenges for businesses operating in or through Cuba-related channels.

United StatesGovernment, Public Sector

Barnes & Thornburg LLP

Weekly Sanctions Update: September 14, 2026

The Treasury Department intensifies economic pressure on Iran through Operation Economic Outcast, suspending aviation licenses and sanctioning dozens of entities while implementing a presumption of denial for Iran-related transactions. Meanwhile, new enforcement actions target Chinese cybercrime platforms, Ecuadorian terrorist organizations, and Israeli settlers, as Congress considers comprehensive Russia-Iran sanctions legislation.

GlobalGovernment, Public Sector