Privacy & Information Security Law Blog

On February 21, 2025, President Trump issued a National Security Memorandum on America First Investment Policy (the “Foreign Investment Memo”) outlining the administration’s foreign direct investment policy, including initiatives for a regulatory “fast track” process, additional scrutiny for Chinese investors, key changes to reviews by the Committee on Foreign Investment in the United States (“CFIUS”) and CFIUS’s use of national security agreements.

The Foreign Investment Memo represents an explicit shift in how the U.S. regulates foreign direct investment. Going forward, partners and allies are likely to see some regulatory burdens ease while investors from China and other countries identified as adverse will see significantly expanded restrictions. Federal agencies have been directed to establish new rules that will specifically target Chinese investment in the United States and new or expanded restrictions on U.S. outbound investment in China in sensitive or emerging technologies. The memo also suggests that the government may reconsider Chinese companies’ access to U.S. capital markets.

Read our full client alert on the Foreign Investment Memo.