Page 8 - The CFIUS Book

THE CFIUS BOOK
details will be provided in regulations that will likely be promulgated between September 2019 and February 2020. At that time, we will update this book with details of the regulations. Until then, throughout this book, we note where FIRRMA has immediately affected the CFIUS process and describe the framework of the changes that will be promulgated under future regulations.
Pilot Programs. FIRRMA empowers the Committee to undertake one or more “Pilot Programs” to implement any of its new authorities under FIRRMA. The institution of a Pilot Program only requires that the Committee Chairperson publish a notice in the U.S. Federal Register of the scope of and procedures for the Pilot Program 30 days before commencing the program. Sheppard Mullin’s CFIUS team will be watching for these Pilot Programs and will be updating clients and contacts around the world as to their content and effect on our Global Trade Law Blog, FCC Law Blog, and Government Contracts Blog.3
A Note Before Starting
The following is not legal advice. We do our best to organize and summarize the most important information related to your CFIUS submission, the review process. Summaries necessarily use shorthand, and reorganizations of information mean we must use generalizations to illustrate the structure of the information.
For detailed analysis of your transaction’s specific set of facts and circumstances, we recommend you consult directly with counsel.
Magnified maps
The CFIUS maps included are busy and contain significant detail. To assist the reader in following these maps, we have include magnified versions of each at the end of this book – look out for the letter identifier in the top right corner of each map.
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