CFIUS reviews foreign deals for US security risk. See the 45-day review clock, how it applies to Israeli tech companies and why Israel is not an excepted state.
CFIUS, the Committee on Foreign Investment in the United States, is the Treasury-chaired interagency committee that reviews foreign investment in US businesses for national security risk. It reaches Israeli tech companies in two ways: when an Israeli buyer acquires a US business, and when a foreign investor buys an Israeli company with US operations. A formal notice runs a 45-day review and a 45-day investigation, per Treasury's CFIUS annual report.
What did FIRRMA change about CFIUS reviews?
The Foreign Investment Risk Review Modernization Act (FIRRMA), signed on August 13, 2018, widened CFIUS from acquisitions of control to certain non-controlling investments and real estate deals, according to Norton Rose Fulbright. Most of the new categories took effect on February 13, 2020.
FIRRMA raised the initial review from 30 to 45 days with immediate effect and kept the investigation at 45 days, per Treasury's CFIUS annual report. It also created a short-form declaration that CFIUS must answer within 30 days, Herbert Smith Freehills Kramer reported.
How long does a CFIUS review take?
A CFIUS notice can take up to 45 days of review and 45 days of investigation, and the President then has 15 days to decide if a transaction is referred, according to Treasury's CFIUS annual report.
| Stage | Length | Source |
|---|---|---|
| Declaration (short form) | 30-day CFIUS assessment | Treasury annual report |
| Notice: initial review | 45 days | Treasury annual report |
| Notice: investigation, if needed | 45 days, with one 15-day extension in extraordinary circumstances | Norton Rose Fulbright |
| Presidential decision, if referred | 15 days after the investigation | Treasury annual report |
FIRRMA also requires CFIUS to comment on a draft notice within 10 business days, per Paul, Weiss, so parties should plan for pre-filing time on top of the statutory clock.
Which CFIUS cases matter most for tech deals?
Three CFIUS cases show how far the committee will go on technology and data deals, including after a deal has closed.
| Case | What happened | Why it matters | Source |
|---|---|---|---|
| Broadcom and Qualcomm | A 2018 presidential order blocked the acquisition of the chip maker Qualcomm | Semiconductor targets draw blocking action | Congressional Research Service |
| Grindr | CFIUS forced Chinese investors to divest from Grindr in 2019 | Personal data on a US app was treated as a security risk | Crowell |
| ByteDance and TikTok | An August 14, 2020 order told ByteDance to divest TikTok's US assets and user data within 90 days | A closed 2017 deal was unwound after review | Federal Register |
The TikTok order and the Crowell analysis both show that CFIUS can act on a transaction it never reviewed before closing, and the 2018 Qualcomm block is summarized by the Congressional Research Service.
What changed at CFIUS in 2025 and 2026?
CFIUS is developing a Known Investor Program, in which eligible foreign investors give CFIUS information before a filing so later reviews move faster, according to Treasury. Treasury issued a request for information on February 6, 2026, with comments due March 18, 2026.
A pilot with frequent filers began in May 2025, per Simpson Thacher. Treasury said the program guarantees no outcomes and that each deal is reviewed case by case. Pillsbury noted that most questions test how close an investor is to adversary countries.
Is Israel an excepted foreign state under CFIUS?
Israel is not an excepted foreign state under CFIUS. Treasury's list names only Australia, Canada and the United Kingdom, all effective February 13, 2020, and New Zealand, effective January 2022, per Treasury's excepted foreign states page.
Israeli investors should therefore assume the standard process applies, and confirm with CFIUS counsel. This is Olam's reading of the framework, not legal advice.
What should Israeli firms with a US footprint do?
Israeli firms with a US footprint should map their US exposure before a deal is on the table, because that exposure is what gives CFIUS jurisdiction. Three steps follow, each to be confirmed with CFIUS counsel:
- List where the company touches the United States: operations, customers, data, and any US parent or subsidiary.
- Document the full investor base so ownership questions can be answered quickly.
- Engage CFIUS counsel at the term-sheet stage, and plan for pre-filing comments before the 45-day clock starts.
CFIUS and Israel FAQ
What is CFIUS?
CFIUS is the Treasury-chaired interagency committee that reviews foreign investments in US businesses for national security risk.
How long does a CFIUS review take?
A notice takes up to 45 days of review plus 45 days of investigation, and a declaration gets a 30-day assessment, according to Treasury's annual report.
Is Israel an excepted foreign state?
No. Treasury lists only Australia, Canada, the United Kingdom and New Zealand.
What is the Known Investor Program?
It is a Treasury program under development that lets eligible foreign investors give CFIUS information in advance to speed later reviews, and Treasury says it guarantees no outcome.
This page is general information, not legal advice. Related Olam coverage: US Export Administration Regulations for Israeli operators, ITAR and Israeli defense exports, the Foreign Direct Product Rule, Israel's SIBAT and defense export licensing and Israel's Ministry of Defense and dual-use technology.
How we report: Olam stories draw on public filings, company disclosures and named sources, checked by our editors. Read our methodology · Corrections
