ARTICLE
3 September 2026

CFIUS In 2026: What The 2025 Annual Report Means For Transaction Planning

D
Dechert

Contributor

Dechert is the law firm that helps business leaders lead. For more than 150 years, we have advised clients on critical issues – from high-stakes litigation to first-in-market transaction structures and complex regulatory matters. Our lawyers in commercial centers worldwide are immersed in the key sectors we serve – financial services, private capital, real estate, life sciences and technology. Dechert delivers unwavering partnership so our clients can achieve unprecedented results.
The U.S. Department of the Treasury's Committee on Foreign Investment in the United States (CFIUS) has released its Annual Report to Congress for 2025, revealing critical data about the Committee's activities and their implications for cross-border transactions. The report provides essential insights for foreign investors and dealmakers navigating the complex landscape of U.S. business acquisitions, highlighting both opportunities and challenges in the current regulatory environment. Understanding these tre
United States Government, Public Sector
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Key Takeaways

  • The U.S. Department of the Treasury’s Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has published its Annual Report to Congress for 2025 (the “Annual Report”), which provides important data on the Committee’s activities through 2025.
  • The Annual Report holds important insights for dealmakers contemplating foreign investment in U.S. businesses. The overall picture is one of continuity, without significant new restrictions on foreign capital.
  • Sophisticated foreign investors continue to close transactions, including in sensitive sectors. But the 2025 data reinforce the importance of underwriting the likely CFIUS outcome early enough to address it in transaction structure, timing and economics.
  • Considering the dynamic foreign investment climate in the United States, dealmakers should evaluate CFIUS and related risks at the start of a transaction and develop a sophisticated strategy to navigate these processes. We can help. Below, we highlight key data and takeaways from the Annual Report that dealmakers should know.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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