U.S. Treasury Moves Ahead With CFIUS “Fast-Track” Process

On February 21, 2025, President Trump issued a National Security Presidential Memorandum titled America First Investment Policy . That memorandum sought to develop ways to support foreign direct investment in the U.S. from friendly allies and partners while carefully reviewing and restricting investment — both inbound and outbound — involving foreign adversaries such as China  (including Hong Kong, and Macau), Russia, Cuba, Iran, North Korea and the current regime in Venezuela.

Among the initiatives directed by the memorandum was the establishment of an “expedited, fast-track process” to speed up and promote greater investment from trusted allied and partner nations.  The investments would be “subject to appropriate security provisions,” including requirements that such investors “avoid partnering with United States foreign adversaries”.

Pursuant to this directive, on May 8, 2025, the Department of the Treasury announced the launch of a fast-track pilot program to facilitate such investment. The first step will be the introduction of a “Known Investor” portal to streamline the investment review process for trusted partners, where information can be collected in advance of filings with the Committee on Foreign Investment in the United States (CFIUS). In a previous April 24, 2025 statement, Deputy Treasury Secretary Michael Faulkender suggested that “maintaining such a knowledge base” would speed up risk assessments by limiting the amount of new information required from repeat investors.

In accordance with the aims of the memorandum, the portal would serve to (a) facilitate new investment from approved partner nations, while (b) allowing CFIUS to focus increased resources on critical assessment of potential national security risks posed by investors who may not have sufficient “verifiable distance and independence from foreign adversaries or threat actors.”

The portal will begin development as a pilot program; no implementation timeline or other details were included in the Treasury announcement.

Phillips Lytle International Business Law attorneys will carefully monitor the program and its process requirements as it moves forward.