Foreign direct investment CFIUS review
In Trade and Geopolitical Risk, foreign direct investment screening under Committee on Foreign Investment in the United States jurisdiction is one of the most operationally demanding compliance obligations U.S.-nexus deals now face. The U.S. Department of the Treasury, as CFIUS chair, has expanded mandatory declaration requirements under 31 C.F.R. Part 800 to cover a wider band of critical technology and infrastructure transactions, and the Office of Investment Security is actively enforcing timelines that leave general counsel little room to improvise. Compliance teams are currently stress-testing deal structures against TID U.S. Business definitions before term sheets are signed, not after.
Watch
- Mandatory declaration deadlines under 31 C.F.R. Part 800.401 for critical technology transactions
- U.S. Department of the Treasury guidance on covered real estate near military installations
- CFIUS mitigation agreement enforcement actions against previously cleared transactions
- Outbound investment screening proposals that could extend review beyond inbound FDI
- Foreign adversary beneficial ownership disclosure requirements in pending deal structures
Recent material activity in Trade & Geopolitical Risk
A selection of recent published briefs; this is not a complete archive.
CBP mandates eCBP portal submission for organization broker license applications effective September 30, 2026
CBP issued CSMS 70013692 on September 25, 2026, requiring all organization customs broker license applications to be submitted through the eCBP portal beginning September 30, 2026. Applications delivered by hand, mail, o…
Read a full sample brief →CBP opens Q4 2026 tariff rate quota for UK automobiles under the US-UK Economic Prosperity Deal
CBP published Quota Bulletin 26-510 on September 25, 2026, establishing the fourth-quarter tariff rate quota for automobiles imported from the United Kingdom. The quota period runs October 1 through December 31, 2026, wi…
Read a full sample brief →CBP opens Tranche 4 of the 2026 Argentina beef quota on October 1 under a presidential proclamation
CBP published Quota Bulletin 26-226 on September 25, 2026, opening the fourth tranche of the 2026 Argentina beef quota. The tranche covers October 1 through December 31, 2026, under an 80,000 metric ton annual allocation…
Read a full sample brief →CBP publishes Quota Bulletin 26-221 governing condiments and mixed seasonings imports for quota year 2027
CBP issued Quota Bulletin 26-221 on September 25, 2026, establishing the tariff-rate quota framework for condiments and mixed seasonings for the period October 1, 2026 through September 30, 2027. The bulletin sets Octobe…
Read a full sample brief →CBP opens 2027 tariff-rate quota for cocoa powder effective October 1, 2026
CBP published Quota Bulletin 26-215 on September 25, 2026, establishing the tariff-rate quota for cocoa powder under HTSUS Chapter 18, Additional U.S. Note 1. The quota period runs October 1, 2026 through September 30, 2…
Read a full sample brief →CBP opens 2027 HELP Act apparel quota period effective October 1, 2026
CBP published Quota Bulletin 26-134 on September 25, 2026, opening the Haiti Economic Lift Program Act quota for apparel goods from October 1, 2026 through September 30, 2027. Entries submitted before 8:30 a.m. Eastern T…
Read a full sample brief →CBP publishes quota bulletin establishing 2027 mixes and doughs tariff-rate quota opening October 1, 2026
CBP issued Quota Bulletin 26-222 on September 25, 2026, establishing the tariff-rate quota for mixes and doughs under HTSUS Chapter 19 for the period October 1, 2026 through September 30, 2027. The quota opens October 1,…
Read a full sample brief →USITC opens full five-year sunset reviews of antidumping and countervailing duty orders on passenger tires from four countries
The USITC announced on September 25, 2026 that it will conduct full five-year sunset reviews of antidumping duty orders covering passenger vehicle and light truck tires from South Korea, Taiwan, and Thailand, and the cou…
Read a full sample brief →ITC institutes Section 337 investigation into DRAM imports on Netlist patent infringement complaint
The U.S. International Trade Commission instituted an investigation on September 25, 2026, based on a complaint filed by Netlist, Inc. on August 11, 2026, alleging patent infringement in imported DRAM devices. The compla…
Read a full sample brief →WTO panel established to review EU carbon border adjustment mechanism and emissions trading scheme at Russia's request
The WTO Dispute Settlement Body agreed on September 25, 2026 to Russia's request for a panel to examine the EU's Carbon Border Adjustment Mechanism and an alleged export subsidy under the EU emissions trading scheme. Thi…
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