CFIUS in 2026: What the 2025 Annual Report Means for Transaction Planning

The U.S. Department of the Treasury’s Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has published its Annual Report to Congress for 2025 (the “Annual Report”), which provides important data on the Committee’s activities through 2025.
The Annual Report holds important insights for dealmakers contemplating foreign investment in U.S. businesses. The overall picture is one of continuity, without significant new restrictions on foreign capital.
Sophisticated foreign investors continue to close transactions, including in sensitive sectors. But the 2025 data reinforce the importance of underwriting the likely CFIUS outcome early enough to address it in transaction structure, timing and economics.
Considering the dynamic foreign investment climate in the United States, dealmakers should evaluate CFIUS and related risks at the start of a transaction and develop a sophisticated strategy to navigate these processes. We can help. Below, we highlight key data and takeaways from the Annual Report that dealmakers should know.

Key Takeaways