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June 6, 2019

Stroock Special Bulletin

By: Chris Griner, Shannon Reaves, Gregory Jaeger, Erin Bruce Iacobucci

On the morning of Wednesday, June 5, Thomas P. Feddo, Deputy Assistant Secretary of the Treasury for Investment Security and presidential nominee for the newly created role of Assistant Secretary of the Treasury for Investment Security,[1] gave his sworn testimony before the U.S. Senate Committee on Banking, Housing and Urban Affairs.  In his written statement,  Mr. Feddo acknowledged the importance of the enactment of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which created the Assistant Secretary position for which he is nominated. He also stressed that he “understand[s] the importance of protecting American innovators’ intellectual property — our nation’s vital economic engine.”

Mr. Feddo fielded several questions from Banking Committee members on both sides of the aisle.  Notably, he commented on the concerns involving state-owned entities attempting to acquire U.S. critical infrastructure, stating that he “absolutely” commits to implementing FIRRMA’s requirements involving state-owned entities, and noting his commitment to building a team to look at and identify ultimate beneficial owners in “non-notified” transactions — transactions that were not voluntarily submitted to CFIUS but still qualify as covered transactions.

Mr. Feddo’s nomination is not yet confirmed, but action on his nomination could occur before Congress takes a recess for the July 4 holiday. Our team will continue to follow his nomination process and keep you updated on CFIUS-related developments as they occur.

For a copy of Mr. Feddo’s testimony, please contact any of the following:


For More Information:

Chris Griner
Shannon Reaves
Gregory Jaeger
Erin Bruce Iacobucci

[1] The White House, “President Donald J. Trump Announces Intent to Nominate and Appoint Personnel to Key Administration Posts, ” Issued on: March 26, 2019; available at:


Gregory Jaeger

Special Counsel

Washington, DC


Erin Bruce Iacobucci

National Security Consultant

Washington, DC