Find a lawyerOur capabilitiesYour career
Locations
Our capabilities
News

Select language:

Locations
Our capabilities
News

Select language:

hamburger menu showcase image
  1. Our capabilities
  2. Foreign direct investment and national security
  3. CFIUS and investment security
CFIUS and investment security

As US scrutiny of inbound and outbound investment intensifies, global investors face a more politicised and unpredictable national security review environment. Global investors face increased uncertainty as the US government intensifies its scrutiny of both inbound and outbound investment. Freshfields provides unmatched guidance on how to best navigate the Committee on Foreign Investment in the United States and US Outbound Investment Security Program.

hero-image-0
Our Chambers-ranked group and lawyers specialize in assessing and mitigating CFIUS risk in cross-border M&A.

Freshfields offers the most experienced and globally integrated Committee on Foreign Investment in the United States (CFIUS) group in the market. Our Chambers-ranked team works seamlessly across our award-winning Corporate and Antitrust groups, combining transaction execution, regulatory strategy and national security insight across jurisdictions.

Our CFIUS bench is anchored by Aimen Mir and Brian Reissaus, the two most recently departed CFIUS career heads, who together account for more than a decade of CFIUS leadership. They are joined by a former leader of the Intelligence Community unit responsible for producing the National Security Threat Assessments that underpin CFIUS decision-making.

Collectively, this group led CFIUS’s review of thousands of transactions, helped write the laws that govern CFIUS and designed the very procedures used to evaluate transactions and monitor compliance. This includes the methodology behind the classified National Security Threat Assessments that underpin decisions and framework used to impose of civil monetary penalties.

With more than 50 years of combined CFIUS experience across government and private practice, our team has been involved in shaping virtually every major development in recent decades across multiple administrations. This includes the 2018 Foreign Investment Risk Review Modernization Act and the 2022 CFIUS Executive Order on CFIUS. While in government, our team managed nearly every review between 2009 and 2023, including every presidential prohibition and divestment order and mitigation agreement during that period. This combination of senior government leadership and private practice experience is unmatched in the market.

We support clients throughout the life cycle of a transaction. This includes structuring deals and analyzing risk with concrete and pragmatic advice, working with clients to ensure responses to information requests are effective in shaping CFIUS’s understanding of the transaction, developing creative and effective mitigation strategies, and negotiating National Security Agreements to maximize the ability of the companies to be commercial and competitive. Our track record includes securing CFIUS clearance in the most challenging and sensitive cross-border transactions, across every major sector and jurisdiction.

Our team also manages transaction-related notifications to the Directorate of Defense Trade Controls under the International Traffic in Arms Regulation and to the Defense Counterintelligence and Security Agency pursuant to the National Industrial Security Program.

Practical leadership on the US Outbound Investment Security Program

Freshfields is also at the forefront of advising on the US Outbound Investment Security Program (OISP). Introduced in 2025, the OISP applies to certain outbound investments into countries of concern, particularly China. Our team includes a former government official directly involved in the program’s design, including the foundational 2025 Executive Order, giving clients first-hand insight into its scope, intent, and operation.

Related capabilities
Antitrust and competition
Artificial intelligence
Foreign direct investment and national security
International trade
National security
Regulatory and compliance advisory
Regulatory and public affairs
Sanctions

Highlight experience

Contacts

Contacts

Meet the team
Washington, DC
Aimen MirPartner | Foreign Investment and National Security | Head of CFIUS Practice
Washington, DC
Brian ReissausSenior Advisor, National Security*
Washington, DC
Christine LaciakSpecial Counsel
Washington, DC
Colin CostelloCFIUS and National Security Advisor
Washington, DC
Tim SwartzAssociate
Washington, DC
Andrew GabelAssociate
Washington, DC
Kate ApplegateAssociate
New York
Mark AppletonAssociate
Washington, DC
Ian AllenAssociate
New York
Keian RazipourAssociate
Meet the team
Awards & recognition
Chambers
International Trade: CFIUS experts
Lexology
Thought Leaders – Global Elite
Foreign Investment Watch
Top Advisors
GCR 100: Foreign Investment Control, 2025
Leading firm
Our thinking

Our thinking

Nov 20 2025
Foreign Investment Monitor - November 2025 | Issue 11

Governments are recasting FDI through a security lens – tightening screening, reviving golden shares and testing new tools. Explore what that means for deals around the world.

Nov 20 2025
The full circuit: FDI and national security in the electric-vehicle era

Electric vehicles have become a new frontier of national security review – linking critical minerals, data and dual-use tech across an increasingly exposed value chain.

Nov 20 2025
The rise of golden shares: A new layer to FDI screening?

“Golden shares” are gaining relevance as a tool for safeguarding national interests in FDI – what has happened and what does this mean for future transactions?

Nov 20 2025
After the mitigation boom: The case for ending zombie CFIUS agreements

Hundreds of legacy CFIUS mitigation agreements still linger. New rules now offer investors a rare chance to amend or terminate outdated national security obligations.

Sep 30 2025
U.S. Government Shutdown: A CFIUS Rundown
The U.S. federal government appears poised for a partial shutdown, which would occur at 12:01am October 1, 2025. Investors should note...
Aug 14 2025
CFIUS 2024 Annual Report – What Does that Data Mean for Investors?
The Committee on Foreign Investment in the United States (“CFIUS”) recently released its calendar year 2024 annual report to Congress...
Jul 17 2025
Jupiter's Chinese Orbit: CFIUS Calls Five Years Later
On July 8, 2025, President Trump signed an order mandating that Suirui International Co., Limited (“Suirui”), a Chinese-owned entity,...
Jul 9 2025
BIS Guidance Targets PRC Advanced Computing Integrated Circuits in “High Probability” Enforcement Regime
On May 13, 2025, the Bureau of Industry and Security (BIS) issued new guidance (the Guidance) highlighting increased scrutiny on...
Jun 18 2025
World war tariff: Is the global trade conflict redrawing the FDI map?

The Trump administration’s drastic tariff strategy has upended the international trade order. What could this mean for foreign investment?  

Jun 18 2025
Nippon Steel’s unprecedented resurrection: Right answer for the wrong reason

President Trump’s revival of the Nippon Steel deal signals a new era of politicized investment review in the United States. As CFIUS becomes a tool of domestic strategy, foreign investors face greater uncertainty – and higher stakes.  

Apr 4 2025
Devil’s in the Details: Hell, High Water, and CFIUS
Delaware Chancery Court Orders Buyer to Execute CFIUS Mitigation Agreement Within 48 hours The Delaware Court of Chancery’s recent...
Feb 24 2025
Trump Issues Investment Policy Directive: A Return to Open Investment Policy, Except for China
I. Summary On February 21, 2025, President Trump issued a national security policy memorandum entitled America First Investment Policy...
Jan 5 2025
Nippon Steel’s Bid for U.S. Steel Blocked under National Security Law
Summary On January 3, President Biden blocked the acquisition of U.S. Steel by Nippon Steel, a Japanese company, on national security...
Dec 2 2024
Final U.S. Outbound Investment Rule: Overview and Key Takeaways for Investors
The Department of the Treasury (“Treasury”) issued its Final Rule (“Rule”) to implement President Biden’s Outbound Investment Executive...
Nov 7 2024
Instant Reaction — CFIUS Under Trump II: Back to the Future
The Committee on Foreign Investment in the United States (“CFIUS”) has aggressively pursued its national security mandate under the Biden...
Nov 5 2024
Proposed Rule would Ban Connected Vehicles and Related Vehicle Components from Chinese and Russian suppliers in the US Market
1. Summary and Overview of the Proposed Rule Summary The Biden administration released a Notice of Proposed Rulemaking (the “Proposed...
Jun 27 2024
U.S. Outbound Investment Restrictions on the Horizon – What You Need to Know
On June 21, 2024, the Department of the Treasury (Treasury) issued a Notice of Proposed Rulemaking (NPRM) to implement President Biden’s...
Apr 17 2024
Proposed Changes to CFIUS Regulations Continue Its Shift Towards a More Enforcement-Focused Mission
On 11 April 2024, the U.S. Department of the Treasury (“Treasury”), in its capacity as chair of the Committee on Foreign Investment in...
Mar 14 2024
New Executive Order Targets Foreign Access to Bulk Sensitive Personal Data and Government-Related Data
What is the headline? On February 28, 2024, the Biden administration released Executive Order (EO) 14117 and an Advance Notice of...
Aug 11 2023
President Biden Issues Outbound Investment Restrictions Executive Order – Small Yard, High Fence?
On Wednesday, August 9, 2023, President Biden issued Executive Order 14105, Addressing United States Investments in Certain National...
Aug 10 2023
CFIUS 2022 Annual Report – Rough Seas Ahead for Investors
The Committee on Foreign Investment in the United States (“CFIUS”) has released its annual report for calendar year 2022.  Although a...
Dec 9 2022
Historic FCC action banning technologies from certain Chinese companies signals continuing U.S. targeting of market-leading Chinese technologies
Over a year ago, Congress passed the Secure Equipment Act of 2021, mandating that the Federal Communications Commission (“FCC”) block the...
Sep 23 2022
New CFIUS Executive Order Reflects Evolved CFIUS National Security Risk Analysis
On 15 September 2022, President Biden signed Executive Order 14083 (Executive Order on Ensuring Robust Consideration of Evolving National...
Jan 14 2022
There’s a new CFIUS Excepted Foreign State, but status will still benefit relatively few investors
Qualifying investors from a list of “Excepted Foreign States” (colloquially referred to as the “whitelist”) enjoy certain privileges...
Jan 10 2022
Freshfields partner Aimen Mir talks CFIUS, FI Monitor with The M&A Journal
Washington-based partner Aimen Mir, who served in several leadership roles in the Committee on Foreign Investment in the US (CFIUS) and...
Jan 6 2022
CFIUS Decision on Magnachip Deal Shows Long Reach of CFIUS
On December 13, 2021, Magnachip Semiconductor Corporation (“Magnachip”), an NYSE-listed Delaware corporation, and Wise Road Capital LTD...
Apr 9 2021
Information and Communications Technology and Services Supply Chain Rule Goes into Effect
As of March 2021, the U.S. Department of Commerce (“Commerce”) has the authority to block or impose conditions on the ordinary course...
Feb 3 2021
Expansion of CFIUS’s monitoring and enforcement capabilities has raised the stakes of getting it right when deciding to voluntarily file a transaction
A recent Wall Street Journal article described how the Committee on Foreign Investment in the U.S. (“CFIUS;” “the Committee”) is using...
Jan 21 2021
New US rules target use of Chinese IT and communications goods and services
The U.S. Department of Commerce (“Commerce”) published proposed rules (“the Rule”), that, if finalized on 22 March, will authorize...
Related capabilities
Foreign direct investment and national securityNational SecurityInternational tradeSanctionsArtificial intelligenceRegulatory and compliance advisoryRegulatory and public affairsAntitrust and competition
Related capabilities
NAVIGATE TO
About usLocations and officesYour careerOur thinkingOur capabilitiesNews
CONNECT
Find a lawyerAlumniContact us
NEED HELP
Fraud and scamsComplaintsTerms and conditions
LEGAL
AccessibilityCookiesLegal noticesTransparency in supply chains statementResponsible procurementPrivacy

Select language:
Select language:
© 2026 Freshfields. Attorney Advertising: prior results do not guarantee a similar outcome