Final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) recently went into effect. FIRRMA (and these new regulations) significantly expand the jurisdiction of the interagency Committee on Foreign Investment in the U.S. (CFIUS) and the related ability of the U.S. president to block or unwind a transaction. In this issue, our International Trade Counsel Richard Elliot discusses some of the important takeaways from these new regulations for private equity firms, including changes in CFIUS filing risks and risks associated with non-U.S. limited partner investments and governance rights.
