The interagency panel within the U.S. Treasury Department that reviews foreign deals for national security risks dropped more guidance recently about investment funds exceptions under its Critical Technology Pilot Program.

Chris Griner, chair of the national security practice/CFIUS/compliance practice group at Stroock & Stroock & Lavan in Washington, D.C., and special counsel Shannon Reaves explained in a special bulletin issued by the firm last week that updated Frequently Asked Questions guidance just released by the Treasury Department’s committee on foreign investment in the U.S., or CFIUS, confirms that the pilot program introduced in November under the Foreign Investment Risk Review Modernization Act of 2018 applies to investments “by or through investment funds.” They said that broader fund exceptions under FIRRMA also apply to the pilot program. 

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