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For these reasons, we expect unilateral review of non-notified transactions by CFIUS to become increasingly common.
Historically, outright rejection of a transaction by CFIUS has been rare.
CFIUS’s focus on personal data is a marked change from just a few years ago, when personal data was rarely considered a primary concern for the Committee.
In our view, the case confirms the continued validity of several recent trends in US government policy and procedures for reviewing foreign investments in the United States.
If Grindr is sold at the request of CFIUS, it will turn out to be one of a handful of cases in which CFIUS’s objections have led to the unwinding of a transaction post-closing.
Although the President can order an unwinding, CFIUS’s strong concerns about a transaction can convince parties to “voluntarily” unwind a deal rather than face a presidential directive to do so.
Reporting suggests that outright rejections of transactions have become increasingly common under the Trump Administration, particularly with respect to deals involving Chinese buyers.
In many cases, the “mitigation” most likely to succeed under current CFIUS practice involving a global business with US operations is to carve the “US business” out from the scope of the proposed investment.
In recent years, the Treasury Department has indicated its desire to strengthen CFIUS’s process for identifying and flagging potentially problematic non-notified transactions.