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ARTICLE · 03 OCTOBER 2025

Potential CFIUS Impacts Of US Government Shutdown

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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As of midnight October 1, 2025, the US Government has undergone a "lapse in appropriated funding," which means that a partial "shutdown" of the US Government is now in effect with respect...

United StatesGovernment, Public Sector
Joseph Falcone
Joseph Falcone
James Robson
James Robson
Christopher Boyd
Christopher Boyd
Daniel Knaap
Daniel Knaap
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Current funding lapse injects timing uncertainty to acquisitions/investments subject to CFIUS jurisdiction

As of midnight October 1, 2025, the US Government has undergone a "lapse in appropriated funding," which means that a partial "shutdown" of the US Government is now in effect with respect to those Government functions without a continuing funding source. It is unclear how long the funding lapse will continue or how it might be resolved (noting the longest US Government shutdown, 35 days, took place in December 2018 – January 2019 during the first Trump Administration).

Transaction parties with deals currently under review by the Committee on Foreign Investment in the United States (CFIUS), or expected to be filed with CFIUS shortly, should be mindful of the following potential impacts of the shutdown on their transactions:

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