Brandon Van Grack spoke to Foreign Investment Watch about the new Enforcement and Penalty Guidelines as one of the key CFIUS takeaways from 2022.
“Enforcement is coming,” Brandon said. “Although the new CFIUS Enforcement and Penalty Guidelines did not change the Committee’s existing authorities, it signals that new enforcement actions are on the horizon. That’s particularly true when paired with the Committee’s enhanced efforts to identify non-notified transactions. The Committee is ramping up enforcement and likely looking to make an example of someone.”
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