ARTICLE · 10 OCTOBER 2019

Treasury Issues Long-Awaited Proposed CFIUS Regulations

O'Melveny & Myers LLP

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On September 17, 2019, the Department of the Treasury issued two sets of proposed regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA).

United StatesGovernment, Public Sector

Theodore Kassinger

Greta Lichtenbaum

David J. Ribner

Mary Patricia Dwyer

On September 17, 2019, the Department of the Treasury issued two sets of proposed regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). As described in our prior alerts— CFIUS Update: Congress Enacts the Foreign Investment Risk Review Modernization Act and CFIUS Update: Interim Regulations, FIRRMA Pilot Program, and Proposed Rulemaking on Emerging Technologies—FIRRMA, enacted in August 2018, expanded and clarified CFIUS's authority in various ways, including jurisdiction to review certain non-controlling investments in US businesses. CFIUS issued interim regulations in October 2018, implementing parts of FIRRMA and a new FIRRMA Pilot Program that requires parties to declare some types of such transactions to CFIUS.

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