After Calm Summer, Expect CFIUS Landscape To Erupt

Law360 (August 28, 2019, 3:37 PM EDT) -- The last few months have been relatively stable in the world of the Committee on Foreign Investment in the United States. But Vesuvius has had stable periods, too.[1] Below we note some observations regarding the current terrain and expectations regarding the forthcoming fall eruption, as CFIUS prepares to issue new rules.

The aftershocks will reshape the CFIUS landscape — the extent of that change, however, may not be clear for many months.

The Current Terrain

CFIUS has not publicly imposed penalties — nor, as far as we are aware, privately imposed penalties — for failure to comply with the current, but temporary, mandatory...

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