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Pay to Play: CFIUS Implementing Fees for Submissions of Voluntary Notices

Client Alert | 1 min read | 03.06.20

On March 4, 2020, the Department of Treasury released a proposed rule to implement section 1723 of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) and require filing fees on voluntary notices to the Committee on Foreign Investment in the United States (CFIUS) for transactions that exceed $500,000. No fee will be required for the abbreviated declarations, whether voluntary or mandatory. The proposal adopts a sliding fee structure from $750 to $300,000 based upon transaction value:

< $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


Some issues for comment over the next thirty days include (1) impact of the fees on the calculus for assessing whether to submit a voluntary disclosure; (2) appropriateness of the proposed tiers; and (3) valuation of certain transactions where it cannot be readily determined from the total transaction price.

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Client Alert | 2 min read | 04.16.26

Federal Circuit Holds Challengers to CICA Stay Overrides Need Not Satisfy Four-Factor Injunctive Relief Test

In a significant decision for government contractors, on April 15, 2026, in Life Science Logistics, LLC v. United States, the U.S. Court of Appeals for the Federal Circuit held that bid protesters challenging an agency’s override of an automatic stay of contract performance under the Competition in Contracting Act (CICA) need not satisfy the demanding four-factor test traditionally required for preliminary injunctive relief.  In so doing, the Federal Circuit clarified that CICA stay override challenges need only demonstrate that the override decision was arbitrary and capricious—nothing more....

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