CFIUS Expands Review Power to Some Non-Controlling Foreign Investment in U.S. Businesses

FCPA risks are usually associated with overseas business activity, but risks also arise when businesses seeking foreign direct investment into the U.S. interact with representatives of state-owned or state-controlled entities. In a recent PLI webinar, Greta Lichtenbaum, a partner at O’Melveny & Myers, and Anne Salladin, a partner at Hogan Lovells, discussed the newly expanded scope of reviews conducted by the Committee on Foreign Investment in the U.S. as detailed in regulations recently promulgated pursuant to the Foreign Investment Risk Review Modernization Act of 2018. See “Minimizing FCPA Risks in Foreign Direct Investment Transactions” (Mar. 20, 2019).

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