On August 6, 2025, the Committee on Foreign Investment in the United States (CFIUS) released its annual report to Congress for calendar year 2024. This annual publication includes the 325 covered transactions—consisting of 209 written notices and 116 declarations—that were filed for CFIUS’s review last year.

CFIUS is an interagency committee authorized to review certain transactions involving foreign investment in the United States and the effect of those transactions on U.S. national security. The Committee is required to provide an annual report to Congress containing specific, cumulative, and trend information related to transaction filing.

In 2024, the volume of CFIUS activity remained high, but the number of covered transactions (325 in total) declined slightly compared to 2023. The reported number of covered transactions reflects the total filing volume, which is slightly inflated since some transactions were withdrawn and refiled, resulting in double counting.

Notices

CFIUS received 209 notices for covered transactions. Of note:

  • 116 notices proceeded to the investigation phase (approximately 56%), which is similar to 2023 when 55% of notices proceeded to the investigation phase.
  • 42 notices were refiled after initially being withdrawn once CFIUS informed the parties that the transaction posed a national security risk. Withdrawing the notice gave the parties additional time to consider the proposed mitigation terms.
  • 7 notices were withdrawn, and the transaction was abandoned. In some cases, the parties did not proceed for commercial reasons. In other cases, CFIUS either (a) informed the parties that it was unable to identify mitigation measures that would resolve the national security concerns or (b) proposed mitigation measures that the parties chose not to accept.
  • 2 presidential decisions were issued related to transactions for which CFIUS initiated a review in 2024.
  • 1 notice was rejected by CFIUS.
  • The Finance, Information, and Services sector continued to produce the most non-real estate notices (53%), followed by the Manufacturing sector (33%).
  • Investors from China filed the most notices, followed by investors from France, Japan, the United Arab Emirates, and Singapore.

Declarations

CFIUS received 116 declarations in 2024, including six related to real estate transactions. In total:

  • 91 were concluded, accounting for over 78% of the declarations filed.
  • 17 requests for notice were made.
  • 1 declaration was withdrawn.
  • CFIUS was unable to conclude seven actions.
  • No declarations were rejected.
  • Investors from Japan, Canada, France, and the United Kingdom filed the most declarations.

Investors from Japan, followed by France, filed the most combined notices and declarations, which was a shift from China having the most CFIUS filings in prior years.

Timelines

Timelines and process efficiency remained relatively stable year-over-year, with moderate increases in review and investigation times in 2024:

  • Draft notices: On average, CFIUS provided written comments within 6.5 days of a draft notice being submitted.
  • Formal written notices: On average, CFIUS accepted formal written notices within 2.7 days for submission.
  • Reviews: CFIUS averaged 46.5 days to complete reviews with a median of 46 days.
  • Investigations: On average, investigations took 87.5 days. The median was 91 days.

Mitigation measures

CFIUS adopted mitigation measures and conditions with respect to 25 notices (approximately 12% of the total number of notices filed), which was down considerably from 2023. The 2024 measures included:

  • 16 mitigation agreements or orders to resolve national security concerns as part of concluding the action.
  • 6 letters granting the withdrawal and abandonment of a proposed transaction with conditions imposed.
  • 1 mitigation agreement to address residual national security concerns related to a transaction voluntarily withdrawn and abandoned by the parties.
  • 1 set of measures imposed to mitigate interim risk.
  • 1 presidential order prohibiting the purchase and requirement the divestment of certain real estate.

New mitigation measures included establishing reporting obligations for foreign sales of covered products.

Other developments

The 2024 report also highlights that:

  • The number of agreements monitored remained relatively steady, but site visits nearly doubled in 2024.
  • According to the Office of the Director of National Intelligence’s (ODNI) 2025 Annual Threat Assessment and the 2018 National Counterintelligence and Security Center Report to Congress, foreign economic, industrial, and cyber espionage by foreign actors like China, Russia, Iran, and North Korea against the United States continues to represent a significant threat to U.S. prosperity, security, and competitive advantage.
  • In November 2024, the Department of Treasury issued two final rules: one expanding real estate jurisdiction and another enhancing information requirements and increasing penalties.
  • Treasury also hosted its third annual CFIUS conference, providing stakeholders with an opportunity to engage with the Committee on a variety of CFIUS topics and trends.
  • In August 2024, CFIUS announced its largest penalty to date, and at the same time launched a new enforcement web page. While not explicitly named, the largest penalty presumably refers to CFIUS’S resolution of an enforcement action against a telecommunications company resulting in a $60 million penalty, following an initial Notice of Penalty issued in 2023.
  • Pursuant to President Trump’s America First Investment Policy memorandum, CFIUS is reviewing its processes, practices, and authorities to ensure it is positioned to address new and evolving threats that can accompany foreign investment, while maintaining the United States’ strong, open investment environment. This directive, coupled with the 2024 report trends, highlights the importance of considering CFIUS early in the deal process, recognizing it as a potential key in both transaction negotiations and the anticipated closing timeline.