On May 8, 2025, the U.S. Department of the Treasury announced “it will establish a fast track process to facilitate greater investment in U.S. businesses from ally and partner sources. This process will include the launch of a Known Investor portal where the Committee on Foreign Investment in the United States (CFIUS), chaired by Treasury, can collect information from foreign investors in advance of a filing. Initially, Treasury will conduct a pilot of this process and build from it over time.”

CIFIUS is especially relevant for 1) GPs who are courting foreign investors for their funds, 2) companies raising capital that are in areas of critical technology, infrastructure, data, and strategic real estate, and 3) PE and other strategic buyers seeking control transactions in areas of critical technology, infrastructure, data, and strategic real estate.

As part of President’s America First Investment Policy, investors will be screened for “independence from foreign adversaries or threat actors” in a pre-filing information submission. This will create a database of known, vetted foreign investors, much like a Known Traveler Number (KTN) is for travelers in the US taking the Transportation Safety Administration (TSA) fast track line.

More information is forthcoming, as the pilot program is being built out.

Jerome Fogel is co-founder of Fogel & Potamianos LLP, a firm recognized by Chambers & Partners’ California Spotlight Guide for excellence in corporate law. A partner in the Corporate Practice Group and Chair of the Sports & Entertainment Group, he is known as an innovator and dealmaker in the legal community. He serves as a concierge general counsel to privately held companies and venture funds, including representation in mergers and acquisitions and capital markets transactions.

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