On May 8, 2025, the U.S. Department of the Treasury (Treasury) announced that it will establish a fast track review process to facilitate greater investment in the United States from ally and partner sources.  Specifically, Treasury stated that the new fast track Committee on Foreign Investment in the United States (CFIUS) review process will include the launch of a “Known Investor” portal through which the CFIUS can collect information from foreign investors in advance of a filing.  Treasury noted that it will first implement the portal as a pilot program.

The portal is the first step in effecting the “fast track” review process described in the February 21, 2025 National Security Policy Memorandum (NSPM) as part of  the Administration’s “America First Investment Policy.”  Please see our previous client alert here.

It remains unclear how Treasury will determine which U.S. allies and partners will be eligible to use the fast track CFIUS review process, and we anticipate additional guidance on this point in the coming months.

Crowell & Moring LLP continues to monitor CFIUS developments and their potential impact on foreign investors and U.S. businesses alike.

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Photo of Caroline Brown Caroline Brown

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

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Photo of Dilan Wickrema Dilan Wickrema

Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the foreign military sales process, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international

…

Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the foreign military sales process, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international trade and national security in the federal government to ensure clients meet their cross-border transaction goals while complying with the applicable laws and regulations. Previously, Dilan served in the Directorate of Defense Trade Controls (DDTC), the Bureau of Industry and Security, and the International Trade Administration.

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