News

U.S. Treasury announces fast track pilot program for foreign investment reviews

14 May 2025

Key takeaways

U.S. Treasury to establish a “fast track” foreign investment review process. It will include a “Known Investor” portal that allows the submission of information in advance of filing with Committee on Foreign Investment in the United States.

The U.S. Department of the Treasury has announced that it will launch a program establishing a “fast track” process for foreign investment reviews undertaken by the Committee on Foreign Investment in the United States.

On 8 May 2025, the U.S. Department of the Treasury (“Treasury”) announced its intent to launch a program establishing a “fast track” process for foreign investment reviews under the Committee on Foreign Investment in the United States (“CFIUS”). The program will introduce a “Known Investor” portal allowing foreign investors to submit information in advance of a filing with CFIUS. According to Treasury, the initiative aims to facilitate the review process for partners and allies that can demonstrate verifiable distance and independence from foreign adversaries or threat actors. The goal of the program, whose key features Deputy Treasury Secretary Michael Faulkender outlined in remarks at a recent conference, is to enhance the United States’ open investment environment without compromising CFIUS’s ability to identify and address national security risks. Treasury will initially establish the fast-track process through a pilot program.

The announcement marks one step in implementing President Trump’s 21 February 2025 National Security Presidential Memorandum on the America First Investment Policy (“NSPM-3”), which directed the creation of an expedited CFIUS review process for investments “from specified allied and partner sources” that “avoid partnering with United States foreign adversaries.”¹ (See our earlier alert on NSPM-3 here.) Treasury has not yet released further details on investor eligibility or the timeline for the launch of the pilot program. Investors considering cross-border transactions should continue to monitor further guidance as Treasury introduces the pilot program for the fast-track process.

Authored byYue-Zhen Li, Zachary Alvarez, Anne Salladin, and Brian Curran.

Next steps

Hogan Lovells can assist you in evaluating the potential impact of developments in U.S. foreign investment regimes on your business. For further information or assistance, please contact any of the listed Hogan Lovells lawyers.

References

¹NSPM-3 defines “foreign adversaries” as the PRC, including the Hong Kong Special Administrative Region and the Macau Special Administrative Region; the Republic of Cuba; the Islamic Republic of Iran; the Democratic People’s Republic of Korea; the Russian Federation; and the regime of Venezuelan politician Nicolás Maduro.