McDermott Will & Emery’s Laura Jehl and Austin Mooney, CIPP/E, break down the U.S. Department of the Treasury’s final rules that implement the Foreign Investment Risk Review Modernization Act. The rules, which went into effect Feb. 13, allow the Committee on Foreign Investment in the United States to review non-controlling foreign investments that involve the “sensitive personal data of United States citizens that may be exploited in a manner that threatens national security.” Under these rules, sensitive data falls into 11 categories, such as credit report information and genetic test results.
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