The Orrick Guide to Foreign Investment Reviews | 2026 Update

2 minute read | March.09.2026

In light of increased geopolitical tensions, the worldwide regulatory landscape for Foreign Investment Review continues to evolve rapidly. A growing number of countries have introduced or strengthened measures to review investments in critical sectors, driven by concerns about the potentially adverse effects that such investments may have on national security or national interests. These regimes often differ widely in scope and timeline, presenting additional complexity for deal makers as they navigate regulatory risk in cross-border investment activity.

The 2026 Orrick Guide to Foreign Investment Reviews answers frequently asked questions regarding investment control regimes in key jurisdictions. Prepared by expert lawyers across our global offices and designed for deal makers, the following jurisdictions are presented in a consistent Q&A format – so you can compare frameworks and spot the issues that matter for your transaction:

China
European Union
France
Germany
Italy
Japan
Singapore
United Kingdom
United States

Read the Guide (177 minute read)

Editors

Harry Clark Partner, International Trade and Investment, Mergers & Acquisitions

Washington, D.C.

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D:+1 202 339 8499
E: [email protected]

Practice:

Technology & Innovation Sector
International Trade and Investment
Mergers & Acquisitions
Responsible Business
Strategic Advisory & Government Enforcement (SAGE)

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Harry Clark Partner

Washington, D.C.

Harry is experienced in areas such as CFIUS/Exon-Florio examinations of foreign investment, military and “dual use” export control regulations (ITAR/EAR), economic sanctions administered by the U.S. Treasury Department (OFAC), customs regulations, the Foreign Corrupt Practices Act, anti-money laundering rules, anti-boycott requirements and defense industrial security requirements. He executes internal corporate investigations regarding trade and investment rules and advises on such rules in the context of corporate transactions.

Additionally, Harry has extensive experience with government contracting matters. His government contracting work has included, for example, design and implementation of U.S. Defense Department renewable energy projects. He also represents broad industry coalitions on major trade litigations and international negotiations. His experience in these areas includes a leading role in what is often considered the largest-ever international trade dispute: the controversy regarding unfair softwood lumber imports from Canada. It has involved myriad administrative proceedings before federal agencies, NAFTA panel appeals, WTO dispute proceedings, judicial proceedings and international settlement agreements.

Harry has represented a coalition of major U.S. oil companies in antidumping and countervailing duty litigation. As a related matter, he pursues policy issues with congressional and executive branch officials and advises on international trade rules (e.g., GATT, WTO agreements and NAFTA).

Chambers 2022 recognizes Harry as a leader in the field of export controls and economic sanctions (Chambers Global and Chambers USA), as well as CFIUS (Chambers USA). Previous editions have also recognized Harry’s achievements regarding his work related to the Foreign Corrupt Practices Act. Clients note that Harry provides “accurate, straightforward guidance incredibly efficiently” and “he has an ability to translate complex legal requirements and rules into business-friendly jargon.”

Jeanine P. McGuinness Partner, International Trade and Investment, FCPA & Anti–Corruption

Washington, D.C.

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D:+1 202 339 8543
E: [email protected]

Practice:

International Trade and Investment
FCPA & Anti–Corruption
Geldwäschebekämpfung und Bankgeheimnis
Mergers & Acquisitions
Responsible Business
Strategic Advisory & Government Enforcement (SAGE)

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Jeanine P. McGuinness Partner

Washington, D.C.

Jeanine’s clients include major U.S. and foreign financial institutions, and pharmaceutical, technology, defense, space, telecommunications, energy, and infrastructure companies, among others.

Examples of Jeanine’s experience include:

Represents clients in preparing voluntary self-disclosures, administrative subpoena responses and license applications, and represents companies in connection with enforcement actions by the Treasury Department’s Office of Foreign Assets Control (OFAC)
Provides policy and compliance advice to clients affected by frequent changes in U.S. sanctions, including sanctions targeting Iran, Cuba, and Russia/Ukraine
Assists foreign purchasers of U.S. companies in national security reviews, including navigating the CFIUS process, through preparation of notices, meetings with CFIUS member agencies, advising on follow-on investigations, and negotiating and implementing mitigation agreements
Assists clients in developing and updating economic sanctions, anti-money laundering, and anti-corruption compliance policies and procedures
Represents financial institutions in connection with U.S. federal and state enforcement actions regarding compliance with U.S. anti-money laundering laws and regulations
Represents lenders, underwriters, borrowers, and issuers in international lending and capital markets transactions regarding sanctions, anti-corruption, and anti-money laundering issues
Advises a U.S. trade association and its member banks regarding U.S. sanctions, anti-corruption, and anti-money laundering issues in lending transactions, and prepares guidance for the industry on these matters
Advises financial institutions on the application of U.S. anti-money laundering regulations, with specific emphasis on customer identification program (CIP)/know your customer (KYC)/customer due diligence (CDD) requirements and suspicious activity reporting requirements
Regularly advises private equity and hedge funds regarding compliance with U.S. anti-money laundering and sanctions laws and regulations, including with respect to appropriate provisions in subscription materials and enhanced due diligence on high-risk investors
Advises clients regarding sanctions-related inquiries from the Securities and Exchange Commission (SEC) and state agencies implementing divestment laws and assists clients in preparing sanctions-related disclosure for inclusion in annual reports to the SEC

Jeanine is ranked in both the CFIUS Experts and Export Controls & Economic Sanctions categories by Chambers USA in 2019, 2020, 2021, and 2022. An interviewee had this to say of their experience working with Jeanine, “I am continuously impressed by her extensive knowledge, excellent communication skills and her ability to wrap her subject matter expertise around the details of the matter and then drive conclusions or recommendations for next steps."

Victoria Newbold Partner, Antitrust & Competition, Strategic Advisory & Government Enforcement (SAGE)

London

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D:+44 20 7862 4702
E: [email protected]

Practice:

Antitrust & Competition
Strategic Advisory & Government Enforcement (SAGE)
Komplexe Streitfälle & Streitbeilegung

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Victoria Newbold Partner

London

Vic’s practice encompasses merger control and foreign direct investment/national security, complex behavioural investigations and antitrust counselling. She has represented clients on some of the most high-profile cases before the European Commission, Competition & Markets Authority, Financial Conduct Authority and other national competition agencies around the world. Vic advises clients across the sectors in which Orrick focuses, but she has a particular specialism in the tech, financial services and retail sectors. She is recommended in The Legal 500 UK as a “rising star” and is ranked as a Next Generation Partner.

Prior to joining Orrick, Vic was senior competition counsel at Bloomberg. There, she was responsible for the global management of competition law matters, showcasing her ability to provide legal support on an international scale and at the intersect of antitrust and fintech regulation.

Neetu Ahlawat Managing Associate, Antitrust & Competition

London

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D:+44 20 7862 4754
E: [email protected]

Practice:

Antitrust & Competition

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Neetu Ahlawat Managing Associate

London

Neetu’s practice encompasses merger control and foreign direct investment, having represented clients in several big-ticket cases requiring complex remedies. She provides guidance on compliance and conducts a range of behavioural investigations for clients across multiple sectors.

Before joining Orrick, Neetu was part of the top-tier competition practice at one of India's largest law firms.

Authors & Key Contacts (+)

Alessandro Amato
Associate | Rome
[email protected]

Allison Bradham
Associate | Washington, D.C.
[email protected]

Chimène Faurant
Partner | Paris
[email protected]

Dr. Benedikt Kamann
Partner | Düsseldorf
[email protected]

Dr. Lars Mesenbrink
Partner | Düsseldorf
[email protected]

Geoffrey Berthon
Partner | Paris
[email protected]

Giji John
Partner | Singapore
[email protected]

Harry Clark
Partner | Washington, D.C.
[email protected]

Hiroki Sugita
Partner | Tokyo
[email protected]

Jeanine McGuinness
Partner | Washington, D.C.
[email protected]