Clifford Chance

CFIUS 2024 Annual Report Shows a Large Drop in Mitigation, Other Encouraging Trends, and a Continued Decline in CFIUS Filings

August 8, 2025

The Committee on Foreign Investment in the United States (“CFIUS”) released its Annual Report to Congress addressing data for calendar year 2024 (“Annual Report”) on August 6, 2025. The Annual Report provides the most comprehensive information available on trends in the CFIUS process. Overall, the 2024 data reflects parties moving through the CFIUS process with fewer hurdles compared to recent years. This trend is likely to continue under the Trump Administration, since the America First Investment Policy issued in February is aimed at encouraging foreign investment from allied investors, including through reducing the use of complex mitigation measures and helping trusted investors move through the CFIUS process more quickly, such as via the new Fast Track pilot program. Most notably, the Annual Report shows that after a significant jump in the frequency of CFIUS requiring mitigation measures to clear transactions during the prior two years, 2024 saw such mitigation decline to its lowest rate since 2015. The frequency of transactions effectively being stopped by CFIUS also decreased. Though 2024 showed some significant improvements for transaction parties, the Annual Report also reflected a second straight year of decline in the total number of CFIUS filings. Given the positive signs in the Annual Report and the Trump Administration seeking to facilitate a welcoming investment environment, transaction parties might find more benefit to voluntary filings and obtaining safe harbor for transactions going forward.

Download PDF