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January 13, 2020

Stroock Special Bulletin

By: Chris Griner, Shannon Reaves, Gregory Jaeger, Christopher R. Brewster, Erin Bruce Iacobucci


This afternoon the Department of the Treasury published final regulations[1] implementing authorities granted to the Committee on Foreign Investment in the United States (CFIUS or the Committee) by the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA).[2]  These regulations become effective on February 13, 2020.

Formal implementation of these regulations will have a significant and immediate effect for foreign investment in the United States, as well as for certain real estate transactions that are not investments in U.S. businesses.  Key issues to be aware of include: a listing of countries now considered “Excepted Foreign States” by CFIUS, requirements for mandatory declarations, and regulations concerning certain real estate transactions, among several other key changes.

The Stroock team will publish a comprehensive Stroock Special Bulletin in the days to come, outlining each of the more significant changes to the CFIUS regulations and providing in-depth analysis to help investors and clients understand what these new rules will mean for them.


For more information, please contact:

Chris Griner

Shannon Reaves

Gregory Jaeger

Christopher R. Brewster

Erin Bruce Iacobucci

[1] See Department of the Treasury, Press Release, “Treasury Releases Final Regulations to Reform National Security Reviews for Certain Foreign Investments and Other Transactions in the United States,” Jan. 13, 2019, available at:

[2] See John S. McCain National Defense Authorization Act for Fiscal Year 2019 (“NDAA”) (Pub. L. 115–232), Subtitle A of Title XVII, (Aug. 13, 2018), available at: