On May 8, 2025, the US Department of the Treasury ("Treasury"), in its role as Chair of the Committee on Foreign Investment in the United States ("CFIUS"), announced the development of a "fast-track" pilot program intended to streamline the CFIUS review process for certain repeat filers. The initiative aims to enhance efficiency in CFIUS's review of transactions that present lower security risks.
Alignment with America First Trade Policy
The development of this fast-track pilot program aligns with the objectives of the Trump Administration's America First Investment Policy ("the Policy"), which was issued on February 21, 2025. The Policy previewed a fast-track process "based on objective standards, to facilitate greater investment from specified allied and partner sources." (We covered the foreign investment implications of the Policy, and the Policy itself more broadly in earlier Legal Updates).
More broadly, the Administration has publicized an intention to
approve transactions involving investors from allied countries more
quickly than in the past. By announcing this pilot program,
Treasury is taking steps to realize these policy directives and
balance the need for robust security protections, with the goal of
fostering investment from allied and partner nations.
In particular, the fast-track program will involve the creation of
a new "Known Investor" portal. While many details are
still to be announced, the portal aims to facilitate the collection
of information on foreign investors in advance of a particular
filing. This approach was recently previewed by Deputy Treasury
Secretary Michael Faulkender, who noted at a conference that CFIUS
would aim "to build up a knowledge base that limits the amount
of information that needs to be resubmitted with each new filing,
which could be a particularly useful tool for repeat filers."
In other words, it appears that the Known Investor portal will
allow foreign investors to submit certain information once, then
use that information repeatedly in subsequent filings.
Implications for Transaction Parties
While the specific details of the pilot program (including eligibility criteria, timing, or the types of investors that may qualify) are still forthcoming, the program makes clear that Treasury will take action intended to improve the efficiency of the CFIUS process. Parties that have previously engaged with CFIUS—or intend to do so in the future—should closely monitor for further guidance as additional details on the pilot program are released.
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