Without fanfare or announcement, the U.S. Department of the Treasury, the agency that chairs the Committee on Foreign Investment in the U.S. (CFIUS), in June added four frequently asked questions (FAQs) regarding investment funds to a pre-existing FAQ document on the department’s website. The additional information provides some confirmation about process, but leaves open our bigger questions about how these new rules will be implemented.
Clarification of a Clarification
As I recently discussed, the new rules on investment funds created in the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) were contained in a section entitled “specific clarification ...