Pay-to-Play 2: CFIUS Filing Fees Go Into Effect May 1, 2020
Client Alert | 1 min read | 04.28.20
The Committee on Foreign Investment in the US (CFIUS) has announced an Interim Final Rule requiring payment of filing fees in connection with any Joint Voluntary Notices submitted on or after May 1, 2020 for “covered transactions” under 31 C.F.R. Part 800 or for “covered real estate transactions” under Part 802. The Interim Final Rule adopts, without change, the sliding scale fee structure as initially proposed, but in light of the COVID-19 pandemic, will continue to accept comments until June 1, 2020.
The fee schedule is:
Total Transaction Value |
Filing Fee |
|
< $500,000 |
$0 |
|
> $500,000 but < $5 million |
$750 |
|
> $5 million but < $50 million |
$7,500 |
|
> $50 million but < $250 million |
$75,000 |
|
> $250 million but < $750 million |
$150,000 |
|
> $ 750 million |
$300,000 |
CFIUS rejected comments seeking to limit the transaction value to just the value of the U.S. business and denied concerns that the lack of any fee for submission of mandatory or voluntary declarations would provide a financial or administrative incentive for CFIUS to fail to conclude action under Section 721 of the Defense Production Act in evaluating such declarations.
Contacts
Insights
Client Alert | 6 min read | 11.25.25
Brussels Court Clarifies the EU’s SPC Manufacturing Waiver Regulation Rules
On November 13, 2025, the president of the French-speaking Brussels Enterprise Court ruled in the long-running battle between Sandoz and Regeneron about the correct interpretation of the EU’s Supplementary Protection Certificate (SPC) Manufacturing Waiver Regulation regarding exports to a non-EU market. The Brussels Court dismissed Regeneron’s claim that Sandoz had provided a defective notification and agreed with Sandoz’s interpretation of the Regulation.
Client Alert | 3 min read | 11.24.25
Client Alert | 7 min read | 11.24.25
Draft Executive Order Seeks to Short-Circuit AI State Regulation
Client Alert | 5 min read | 11.24.25
Qatar Enacts Law No. (22) of 2025 on Persons with Disabilities

