The Committee on Foreign Investment in the United States (CFIUS or the Committee) recently published its 2025 Annual Report, which provides information regarding transactions reviewed by CFIUS during 2025.[1] Key takeaways from the 2025 Annual Report are below.
- CFIUS faced operational challenges in 2025 due to lapses in appropriations. During funding lapses, statutory deadlines were tolled and the Committee was not able to accept new transactions. These lapses tolled deadlines in active cases for more than 120 days in total through 2025.
- CFIUS launched the Known Investor Pilot Program to expedite the review process for repeat filers. The Treasury Department initiated the pilot program in 2025 after President Trump called for “an expedited ‘fast-track’ process” for foreign investments in his America First Investment Policy. The program’s purpose is to collect information from foreign investors who repeatedly file with CFIUS in order to streamline future reviews. As discussed in our prior blog post, CFIUS engaged with a representative sample of foreign investors, asking them to complete a voluntary and confidential questionnaire and to provide feedback regarding ways to increase efficiencies during the review process.[2]
- The Treasury Department memorialized the Department of Agriculture’s role as a member of CFIUS for agriculture-related transactions through a Memorandum of Understanding. Pursuant to the Memorandum signed on July 8, 2025, the Secretary of Agriculture serves as a member of CFIUS in cases involving “agricultural land, agriculture biotechnology, or the agriculture industry (including agricultural transportation, agricultural storage, and agricultural processing).” The Department of Agriculture’s participation in CFIUS began in 2024 on an ad hoc basis.
- 2025 saw another increase in short-form declarations, while full notice filings continued trending slightly downward. During 2025, CFIUS reviewed 140 declarations and 207 notices, compared with 116 declarations and 209 notices during 2024 and 109 declarations and 233 notices during 2023.
- CFIUS cleared declarations at a lower rate. During 2025, CFIUS cleared 92 of the 140 declarations it reviewed, or about 66 percent. CFIUS cleared approximately 78 percent of declarations during 2024, 75 percent during 2023, and 58 percent during 2022.
- CFIUS was unable to conclude action on 11 declarations and requested full notice filings for 36 of the 140 declarations filed during 2025. One declaration was withdrawn.
- Investors from Japan once again accounted for the highest number of declarations (18), following by investors from France (14), Singapore (13), Germany (12), South Korea (11), the United Kingdom (11), and Canada (9).
- The percentage of notices proceeding to the investigation period remained stable from 2024 to 2025. Of the 207 notices filed during 2025, 114 (approximately 55 percent) proceeded to the additional 45-day investigation period. This figure is similar to the percentage of notices that proceeded to the investigation period during 2024 (just over 55 percent).
- CFIUS continues to provide comments on draft notices and accept formal written notices promptly. During 2025, CFIUS provided written comments on draft notices in less than six business days and accepted formal notices in less than four business days after submission, on average. The turnaround time for comments on draft notices decreased by about one business day from 2024, while the turnaround time for acceptance of formal notices increased by about one business day.
- Some turnaround times in 2025 were delayed due to lapses in appropriations. The above figures do not include days during which the statutory deadline was tolled.
- The percentage of notices withdrawn increased in 2025 compared to 2024. Of the 209 notices filed during 2025, 61 notices (29 percent) were withdrawn, compared to 23 percent during 2024 and 24 percent during 2023. Of those, 51 notices were refiled in either 2025 or 2026. Seven transactions were abandoned after CFIUS either informed the parties that CFIUS was unable to identify mitigation measures that would address its national security concerns or CFIUS proposed mitigation measures that were unacceptable to the parties. Three of the withdrawn notices were abandoned by the parties for commercial reasons.
- The percentage of cases for which mitigation was imposed remained stable from 2024 to 2025. CFIUS sought to impose mitigation measures and conditions in connection with 25 cases (just over 12 percent) during 2025, compared to 25 cases (just under 12 percent) during 2024. Of the 25 cases in 2025, 15 resulted in CFIUS concluding action after entering into the mitigation agreements, while another ten (i.e., the cases referenced in the preceding paragraph) resulted in abandonment of the transaction.
- Two presidential decisions[3] were issued regarding transactions that CFIUS reviewed during 2025, the same number as issued in 2024.
- On July 8, 2025, President Trump issued an executive order requiring Suirui International Co., a Chinese company, to divest its interests and rights in Jupiter Systems, LCC, a California-based company specializing in video processing technology, following a review by CFIUS.
- On January 2, 2026, following completion of a CFIUS review process, President Trump ordered HieFo Corporation, a Delaware company that was determined to be controlled by a Chinese national, to divest its ownership of digital chip and wafer-related assets (including a semiconductor manufacturing facility) that it acquired from EMCORE Corporation (EMCORE), a New Jersey company, in 2024.
- There were fewer inquiries into non-notified transactions, and a slightly lower share of inquiries led to requested filings. During 2025, CFIUS opened inquiries into 62 non-notified transactions, and of those, CFIUS requested filings for nine transactions. The number of inquiries is a decrease from 2024 (76 inquiries). The percentage of inquiries resulting in a requested filing decreased during 2025 to 15 percent, down from 16 percent during 2024 and from 21 percent during 2023.
- Chinese investors once again filed the most CFIUS notices during 2025. Investors from China filed 33 CFIUS notices during 2025, followed by investors from Japan (23), the United Arab Emirates (18), Canada (15), Germany (14), Israel (12), France (10), and Singapore (10).
Cleary summer associate Matt Jelen also contributed to this article.
[1] Cleary’s summary of the CFIUS 2024 and 2023 Annual Reports can be found at: https://www.clearytradewatch.com/2025/08/cfius-releases-2024-annual-report-key-takeaways/ and https://www.clearytradewatch.com/2024/08/cfius-releases-2023-annual-report-key-takeaways/.
[2] We discussed the Treasury Department’s Request for Information seeking public input on the Known Investor Program here: https://www.clearytradewatch.com/2026/02/treasury-seeks-public-input-on-cfius-known-investor-program-and-additional-process-efficiencies/.
[3] We discussed President Trump’s presidential decisions in our previous blog posts, which can be found at: https://www.clearytradewatch.com/2025/07/president-trump-issues-order-requiring-chinese-company-to-divest-interest-in-u-s-video-processing-technology-company/ and https://www.clearytradewatch.com/2026/01/president-trump-issues-order-requiring-hiefo-corporation-to-divest-ownership-of-digital-chip-and-wafer-related-assets/.