CFIUS Handles 347 Filings as Foreign Deal Scrutiny Stays High

US Department of the Treasury

WASHINGTON, DC — The Committee on Foreign Investment in the United States handled 347 notices and declarations in 2025, with more than half of formal notices advancing to investigation as U.S. scrutiny of foreign investment remained concentrated on transactions involving technology, services and manufacturing.

The Treasury Department, which chairs CFIUS, released the committee’s 2025 Annual Report to Congress on Friday. The report covers transactions for which CFIUS completed a review or assessment during the calendar year.

CFIUS reviewed 207 written notices that it determined were covered transactions, including seven involving real estate. Of those notices, 114 proceeded from the initial review stage to a subsequent investigation.

The committee separately assessed 140 declarations, a shorter form of filing that can be voluntary or mandatory depending on the transaction. Fifty-one were subject to mandatory filing requirements.

CFIUS concluded action on 92 of those declarations without requiring a full notice. It requested notices in 36 cases and was unable to conclude action based on the declaration in 11. One declaration was withdrawn.

Despite lapses in federal appropriations that tolled active case deadlines for more than 120 days during 2025, CFIUS cleared 67% of distinct transactions during either the 30-day declaration assessment or the initial 45-day notice review, excluding days affected by the funding interruptions.

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The funding lapses also delayed CFIUS from accepting new transactions and created uncertainty for investors and businesses relying on predictable review timelines, according to the report.

National-security concerns resulted in mitigation requirements for a portion of the caseload. CFIUS concluded action on 15 notices after adopting mitigation agreements or orders and imposed mitigation agreements on another two transactions that were ultimately withdrawn and abandoned.

Sixty-one of the 207 notices were withdrawn. Fifty-one were subsequently refiled, while 10 transactions were abandoned for commercial reasons or after CFIUS either could not identify acceptable mitigation or proposed measures the parties declined to accept.

Two transactions reviewed by CFIUS in 2025 resulted in presidential decisions. Three notices were rejected by the committee.

China accounted for the largest number of notice filings by foreign acquirer home country or economy, with 33, or 17% of the 2025 total. Japan followed with 23, the United Arab Emirates with 18 and Canada with 15.

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Those figures count total filings rather than distinct transactions and can include transactions that were withdrawn and refiled or involved acquirers from multiple countries. When transactions were counted only once, Japan, the United Arab Emirates and Canada accounted for the highest numbers in 2025, according to the report.

Among declarations, Japanese investors accounted for the most in 2025 with 18, followed by France with 14 and Singapore with 13.

Finance, information and services accounted for half of the 200 non-real-estate notices during the year, while manufacturing represented 39%. Mining, utilities and construction accounted for 7%, and wholesale, retail and transportation represented 5%.

CFIUS also reviewed 166 covered transactions involving acquisitions of U.S. critical-technology companies in 2025. The figure includes cases that may have been refiled or originated as declarations.

Enforcement extended beyond transactions voluntarily presented for review. CFIUS identified thousands of potentially non-notified transactions, investigated 90 to determine whether formal inquiries were warranted and opened 62 official inquiries. The committee requested filings in nine cases, while parties in two others voluntarily filed after CFIUS outreach but before receiving a formal request.

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At the end of 2025, CFIUS was monitoring 234 mitigation agreements and conditions. Monitoring agencies conducted 40 compliance site visits during the year, and the committee issued two formal findings of noncompliance involving mandatory filing requirements.

Treasury also launched a Known Investor Pilot Program intended to collect information from certain foreign investors before potential transactions are filed, with the goal of making reviews involving investors from U.S. allies and partners more efficient.

“For the past 50 years, CFIUS has safeguarded U.S. national security by identifying and addressing risks associated with certain foreign investments,” Assistant Secretary for Investment Security Chris Pilkerton stated.

CFIUS operates under Section 721 of the Defense Production Act and can review certain foreign investments for national-security risks. If those risks cannot be resolved through other authorities or mitigation measures, a transaction can be referred to the president, who has authority to suspend or prohibit it, including by ordering divestment.

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