The Situation: The Pilot Program, recently
announced by the Committee on Foreign Investment in the United
States ("CFIUS"), mandates filing declarations with CFIUS
in connection with certain foreign investments in U.S. businesses
that possess "critical technology."
The Development: After two months, a number of
useful observations can be shared regarding CFIUS'
implementation of the Pilot Program.
Looking Ahead: Additional clarity relating to
certain elements of the Pilot Program is expected from CFIUS.
The Committee on Foreign Investment in the United States has now
responded to companies that submitted the first mandatory
declarations under the recently announced Pilot Program for foreign
investments in U.S. critical technology companies, which Jones Day
first reported on
here.