3) Will there be a process for determining whether a transaction is prohibited? No. Unlike the CFIUS process, where transaction parties can submit a declaration or notice to obtain clearance for a transaction (or clearance with mitigation), there is no ...
CFIUS has in recent years also heavily scrutinized transactions in which a foreign party could gain access to personal information of U.S. citizens, especially when it is in bulk form. FIRRMA codifies CFIUS’ jurisdiction over transactions that provide investors access to the sensitive personal data...