The table in the CFIUS annual report that puts Chinese investors top of the filing list also says, four paragraphs later, that on distinct deals they are not
The same passage does both things, four paragraphs apart, and the second half is the one nobody quotes.
Treasury published the Committee on Foreign Investment in the United States annual report to Congress for calendar year 2025 on Friday. Its country table shows investors from China filing the most covered notices, 33 of them, 17 percent of the total, ahead of Japan on 23. Then the report explains what that table counts: total filing volume, including notices that were withdrawn and refiled, which means a single deal can appear more than once. Counting distinct transactions instead, the report says the highest numbers in 2025 came from investors from Japan, the United Arab Emirates and Canada.
The volumes
CFIUS reviewed or assessed 347 covered transactions last year. That splits into 207 written notices and 140 declarations, the abbreviated filing the Committee has 30 days to answer.
Notices were almost flat on the year, 207 against 209. Declarations rose, from 116 to 140. Of the 207 notices, 114 went on to a full investigation, and 61 were withdrawn. Fifty-one of those withdrawals were followed by a fresh notice, 37 refiled in the same year and 14 already in 2026. Ten were withdrawn and abandoned. Three notices were rejected outright.
Where the declarations went
The short form is getting bounced more often, and this is the most useful single change in the report.
Of the 140 declarations, 92 ended with the Committee concluding all action, which is the outcome a filer wants. But 36 came back as a request for a written notice, and a further 11 with the Committee unable to conclude action on the declaration. In 2024 the request-for-notice number was 17 out of 116. That is roughly a quarter of declarations sent back for the long form, against roughly a sixth the year before.
Two presidential decisions
The President issued decisions on two transactions for which CFIUS opened a review in 2025, and on two in 2024. The same column of the same table reads zero for 2021, zero for 2022 and zero for 2023.
Mitigation was applied more often than the headline number suggests. Fifteen notices concluded with a mitigation agreement or order. Two more carried agreements addressing residual concerns even though the parties withdrew and abandoned the deal, five withdrawal letters imposed conditions without a formal agreement, and two notices drew interim measures while the review ran.
The deals nobody filed
The report's non-notified section describes a funnel. Thousands of potential transactions identified from interagency referrals, public tips, classified reporting, media reports, self-disclosures, congressional notifications and commercial databases. Ninety investigated far enough to decide whether to open an inquiry. Sixty-two official inquiries opened by Treasury. Nine filings requested.
And two cases where the parties, having heard from the government, filed before they were asked to.
