In an article published in the November 2018 issue of the ACC Docket, I co-authored an article with Elliot Burger, senior legal counsel at Linamar Corporation in Ontario, Canada discuss the expanding role of the Committee on Foreign Investment in the United States (CFIUS).  CFIUS is the U.S. government committee that reviews transactions that could result in control of a U.S. business by a foreign person in order to determine whether the transaction could harm U.S. national security.

In the article, we specifically examine lessons learned from three transactions that failed due to CFIUS concerns:

  1. The September 2017 proposed acquisition of U.S.-based Lattice Semiconductor by a subsidiary of the Canyon Bridge Fund, a private equity fund backed by Chinese investors.
  2. The January 2018 proposed acquisition of U.S.-based MoneyGram International by Ant Financial, a Chinese company owned by Alibaba.
  3. The March 2018 proposed acquisition of U.S.-based Qualcomm by Broadcom, a Singapore-based rival of Qualcomm.

The article also addresses how new legislation, the Foreign Investment Risk Review Modernization Act (FIRRMA), will impact how CFIUS operates.  As noted in the article, “FIRRMA creates new obligations for transaction parties and a broader set of mandates by which CFIUS will operate. As a result, more CFIUS filings will be made, and thus more transactions will be exposed to CFIUS review.”

The full article, “Foreign Acquisition of US Assets: Aggressive Actions Likely to Continue,” was published in the November 2018 issue of ACC Docket.

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Photo of Thad McBride Thad McBride

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP)…

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP), and the Foreign Corrupt Practices Act (FCPA). He also advises clients on anti-boycott controls, and assists companies with matters involving the Committee on Foreign Investment in the United States (CFIUS). Thad supports international companies across a range of industries, including aviation, automotive, defense, energy, financial services, manufacturing, medical devices, oilfield services, professional services, research and development, retail, and technology. Beyond advising on day-to-day compliance matters, Thad regularly assists clients in investigations and enforcement actions brought by government agencies, including the U.S. Department of Justice (DOJ), the U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department Directorate of Defense Trade Controls (DDTC), Customs and Border Protection (CBP), the U.S. Commerce Department Bureau of Industry & Security (BIS), and the Securities & Exchange Commission.