On August 7, the Committee on Foreign Investment in the United States (CFIUS) released its Annual Report to Congress addressing data for calendar year 2025 (Annual Report). Covering the first year of the second Trump Administration, the Annual Report demonstrates that CFIUS continues to be active with both transaction reviews (declarations and full notices) and monitoring and enforcement activities and largely shows continuity with the 2024 report. The consistency is notable given the prolonged US government shutdown in late 2025, which was the longest in US history and significantly disrupted CFIUS operations for about a month and a half. That said, several data points likely reflect the effects of the shutdown. These include a decline in non-notified inquiries, an increase in withdrawals and refilings, and a rise in the number of case extensions. Aside from what is indicated in formal statistics, the shutdown also delayed the CFIUS process for numerous transactions. With respect to other trends, total CFIUS filings increased in 2025 after decreases in the prior two years. This was driven by a spike in declarations, though a higher percentage of declarations resulted in requests for a full notice than in recent years. Encouragingly for transaction parties, the decreased rate of mitigation being required to clear transactions in 2024 continued in 2025. At the same time, the number of transactions effectively blocked by CFIUS ticked up, potentially due to an increase in more sensitive filings. Consistent with US policy to remain the world’s premier destination for foreign capital, CFIUS continued to clear most transactions without mitigation.
