Alan Enslen and Julius Bodie

As we previously reported in our August 9th blog post the new CFIUS requirements were approved by the U.S. House and Senate with the passage of the Foreign Investment Risk Review Modernization Act (FIRRMA).

Since then, on November 10, 2018, the FIRRMA pilot program went into effect, implementing two key provisions of the legislation: expanded jurisdiction rules that target critical technologies and new mandatory filing requirements. CFIUS’s jurisdiction now includes reviews of certain investments by foreign persons that do not necessarily constitute an acquisition of “control” of a U.S. business (FIRRMA refers to these as “other investments”). (more…)