On February 21, 2025, President Donald J. Trump released a National Security Presidential Memorandum (“Memorandum”) proposing broad revisions to the inbound and outbound investment screening review processes maintained and administered by the U.S. Department of the Treasury (“Treasury”), including the Committee on Foreign Investment in the United States (“CFIUS”).
The Memorandum simultaneously seeks to relax and heighten regulations and scrutiny of a broad array of investments and transactions.
- To facilitate and promote inbound U.S. investment and capital flows from investors based in U.S. allied countries, the Memorandum proposes to reduce regulatory scrutiny and expedite review timeframes, including for CFIUS.
- At the same time, the Memorandum seeks to significantly increase U.S. government regulatory oversight and CFIUS scrutiny of inbound investments from entities and individuals located in “foreign adversary countries,” which include China and Russia.
- Finally, in an effort to limit the ability of U.S. businesses and persons to invest into China, the Memorandum proposes to broaden Treasury’s recently implemented outbound investment regulations by subjecting additional industry sectors in China and new categories of transactions to the regulations.
