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  1. Our thinking
  2. Foreign Investment Monitor - November 2025 | Issue 11

Foreign Investment Monitor

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.

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National security has become the dominant lens for global investment.

Sectors that governments once actively courted for foreign investment due to its economic benefits – from data and infrastructure to minerals, energy, advanced technology, and consumer electronics – are now subject to intensive screening on the basis of national security.

This edition of Foreign Investment Monitor examines how FDI policy is adapting as industrial strategy, geopolitics and economic resilience converge.

  • The full circuit: FDI and national security in the electric-vehicle era

EVs now sit at the intersection of technology, infrastructure and data security – making them a new focal point for investment scrutiny.

  • The rise of golden shares: A new layer to FDI screening?

From US Steel and Doliprane to Royal Mail , governments are reviving golden shares to retain control over strategic assets – signaling a broader move toward state participation in the market.

  • Balancing security and growth: Investment screening under the UK’s Modern Industrial Strategy

The UK aims to simplify its regime while tightening control of critical sectors, from semiconductors to water.

  • Navigating the new landscape: The EU’s Foreign Subsidies Regulation and its merger tool

The FSR’s reach is testing how Europe can safeguard fair competition without deterring capital – a pivotal moment for cross-border M&A.

  • After the mitigation boom: The case for ending zombie CFIUS agreements

Hundreds of outdated national security agreements continue to burden investors. New regulatory powers offer a rare chance to streamline obligations and refocus on genuine security risks.

  • Europe oversees the tightening of its FDI net, but unity remains elusive

The EU’s screening framework is expanding fast but remains fragmented, as Brussels seeks coordination while Member States guard sovereignty.

Freshfields also co-edited Lexology’s In Depth: Foreign Investment Regulation, which explores the same global shift toward security-driven investment policy.

Across jurisdictions, a pattern is clear: investment policy is no longer only about market access but about strategic influence. Governments are learning to act like investors; investors, in turn, must learn to think like governments.

November 2025 articles

Executive summary
1. The full circuit: FDI and national security in the electric-vehicle era
2. The rise of golden shares: A new layer to FDI screening?
3. Balancing security and growth: Investment screening under the UK’s Modern Industrial Strategy
4. Navigating the new landscape: The EU’s Foreign Subsidies Regulation and its merger tool
5. After the mitigation boom: The case for ending zombie CFIUS agreements
6. Europe oversees the tightening of its FDI net, but unity remains elusive
7. New Foreign Investment Regulation: Navigating the new era of strategic and economic security

Past editions

Foreign investment monitor archive

Related capabilities

Foreign direct investment and national security

Contacts

View all team
London, Hong Kong, Dublin

Alastair Mordaunt

Partner
Washington, DC

Aimen Mir

Partner | Foreign Investment and National Security | Head of CFIUS Practice
Berlin

Frank Röhling

Partner
London

Michele Davis

Partner | Global Co-Head of Tech, Media and Telecoms
Washington, DC

Brian Reissaus

Senior Advisor, National Security*
Hong Kong

Ninette Dodoo

Partner
Berlin

Uwe Salaschek

Counsel
London

Sarah Jensen

Counsel
Amsterdam

Winfred Knibbeler

Partner
Washington, DC

Colin Costello

CFIUS and National Security Advisor
Vienna

Maria Dreher-Lorjé

Partner
London, Dublin, Brussels

Alex Potter

Partner
Milan, Rome

Ermelinda Spinelli

Italy Managing Partner
Paris, Brussels

Jérôme Philippe

Partner
Washington, DC

Christine Laciak

Special Counsel
Madrid

Álvaro Iza

Partner
Düsseldorf

Juliane Hilf

Partner
Amsterdam

Paul van den Berg

Partner
Rome

Gian Luca Zampa

Partner
Brussels

Andreas von Bonin

Partner
Madrid

Ignacio Borrego

Of Counsel
Tokyo

Kaori Yamada

Partner
Paris

Pascal Cuche

Public Law
Vienna

Stephan Denk

Partner
Hong Kong

Ziqi Zhou

Associate
View all team
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