Annual Report Shows CFIUS Remains Busy in 2025 Despite Lapse of Government Funding
The Committee on Foreign Investment in the United States (CFIUS) had another eventful year of reviewing transactions involving foreign investors in the United States. Released in August 2026, the CFIUS 2025 annual report covers the first calendar year of the Trump Administration and its America First Investment Policy. The report shows a CFIUS that remained active despite the longest government shutdown in US history.
The CFIUS caseload remained significant in 2025. CFIUS reviewed a total of 347 covered transactions in 2025, an increase from 325 in 2024 but still down from a peak of 440 in 2022. The report notes that the lapses in government funding in 2025 presented serious challenges to the Committee’s operations, forcing it to toll deadlines for more than 120 days in total and delaying its ability to accept new transactions. Despite this, after excluding days tolled due to lapses in appropriations, CFIUS cleared 67% of all covered transactions within the 30-day period for short-form Declarations or the first 45-day review period for long-form Notices.
Of the 347 covered transactions, CFIUS reviewed 207 long-form Notices, roughly the same level as the 209 it reviewed in 2024. Meanwhile, the number of short-form Declarations jumped from 116 in 2024 to 140 in 2025. Among the 140 Declarations in 2025, CFIUS requested formal Notices in roughly a quarter (36) of them, an increase from roughly 15% in 2024 but still down from one-third in 2022. Among the 207 Notices, approximately 55% (114) progressed into the second 45-day investigation period. CFIUS adopted mitigation measures and conditions with respect to 25 Notices filed, 15 of which were mitigation agreements entered upon clearance.
In terms of total filing volume (including transactions which were withdrawn and refiled), investors from China (including Hong Kong) once again accounted for the highest number of Notices (33 Notices), followed by Japan (23), the United Arab Emirates (18), and Canada (15). However, measured on a transaction basis (i.e., not counting refilings), investors from Japan, the United Arab Emirates, and Canada made up the top three. As for Declarations, Japan once again led with 18 Declarations, followed by France (14) and Singapore (13). In comparison, investors from China submitted only five Declarations.
The report also notes the launch of the Known Investor Pilot Program in 2025. CFIUS launched this program to implement part of the Trump Administration’s America First Investment Policy, which directed CFIUS to create a “fast-track” process to facilitate investments from trusted, friendly jurisdictions while maintaining heightened scrutiny on China-linked investments. As the program moves toward the formal rulemaking process, parties with established compliance records and favorable nationalities could benefit from expedited timelines and reduced friction in future CFIUS reviews.
As many expected, the annual report shows that CFIUS’s work remained active throughout 2025, despite lapses in funding and staffing shortages. Given CFIUS’s continued prominence and its rollout of the fast-track process, foreign investors, US businesses and sellers should remain mindful of CFIUS exposure as early as possible in the transaction process, and closely monitor and assess how the changes in CFIUS policy will affect future transactions.
