A solar farm. A pork facility. A hotel. A dating app. These things might not seem like they are connected, but they have more to do with national security than one might think. Foreign entities have been steadily acquiring American land and intellectual property for decades, quietly building leverage that can be activated when needed. In this ongoing shadow struggle, the Committee on Foreign Investment in the United States (CFIUS) stands out as a critical instrument in the United States’ broader economic warfare toolkit, enabling strategic leverage over adversaries through control of capital and access.
What is CFIUS?
CFIUS is a little-known U.S. government committee that wields considerable power in protecting U.S. equities from foreign risks at home. Led by the U.S. Department of the Treasury, CFIUS is an interagency effort that reviews foreign investment in the U.S. to identify and protect against national security risks. Broadly speaking, CFIUS focuses on two aspects of foreign ownership: information and location, which refer respectively to the contents of what a foreign government may obtain or access, and the inherent access a company may have due to owning property or facilities near sensitive installations or critical infrastructure.
Although CFIUS has existed since 1975, it was a relatively quiet and often overlooked office until Congress passed major reforms in 2018 under the Foreign Investment Risk Review Modernization Act (FIRRMA) that expanded the committee’s jurisdiction and enforcement powers. Then, as the United States and global economies reeled from the onset of COVID-19, the federal government surged new powers, funding, and staffing into CFIUS. Today, CFIUS operates with far greater reach and resources, aggressively reviewing transactions tied to critical infrastructure, sensitive data, healthcare, and emerging technologies to safeguard national security.
National Security Manifests in Many Forms
The manifestation of contemporary risks to U.S. national security can sometimes sound like a futuristic spy flick. Take, for instance, a solar farm that a foreign entity sought to buy. There are two salient concerns. First, the location of the solar facility was in the flight path of sensitive U.S. military air traffic, giving an adversary the ability to collect information about flight schedules and characteristics. To exemplify the point, think about the flight of B-2s that bombed Iran on June 22, 2025. Media coverage of the strikes explained the elaborate ruse of several B-2s taking off from Whiteman Air Force Base in Missouri and flying in one direction, only to have a small subset then break off and fly in the opposite direction toward the targets. The Pentagon was concerned that anyone watching the base or flight path would see the aircraft take off and deduce that a strike was underway, putting the operation and the fight crews in danger. The purchase of a solar facility or any infrastructure with visibility of such sensitive flight paths could yield significant intelligence to an adversary. This is but one example of concerns over proximate real estate to sensitive U.S. government locations.
The second national security concern posed by a solar farm, or practically any site containing critical energy infrastructure, is that it could be used to collect intelligence on any nearby U.S. military bases. Such purchases could give a foreign entity control over critical energy infrastructure that supports or powers the base, creating potential vulnerabilities in the event of conflict or geopolitical tension. Additionally, proximity to the base could enable technical surveillance or data collection activities, posing significant intelligence and operational security risks.
Such facilities have found themselves before CFIUS on several occasions. In one well-reported case, China-based Fufeng Group’s interest in building a new corn milling facility in Grand Forks, North Dakota, was cause for local excitement—bringing the prospect of new jobs and other local economic lift. However, it triggered CFIUS concerns about the possible implications for nearby Grand Forks Air Force Base and Cavalier Space Force Station. In many cases, the justification of CFIUS involvement may be obvious; however, ulterior motives of foreign nations and the utilization of classified information can often be opaque to the unwitting eye.
Even the sale of a Manhattan hotel has the potential to become a national security concern. In 2014, Anbang Insurance Group—a Chinese company—sought to buy and renovate the Waldorf-Astoria. The proposed renovations have raised concerns about possible Chinese cyberespionage, particularly given that the hotel regularly houses senior U.S. officials and frequently serves as a base for diplomats and foreign leaders during the UN General Assembly and other events. Hospitality facilities, particularly in New York—where the United Nations is headquartered and diplomats regularly visit—are ripe for conducting espionage against third-party nations.
CFIUS also took an interest in the 2013 plan by Shuanghui International Holdings Limited to purchase Smithfield Ham, the world’s largest pork producer. The sale prompted concerns from political leaders that China could choke off U.S. consumer access to pork and raise overall food prices if a conflict were to occur. In September 2013, U.S. Senator Debbie Stabenow, then the chair of the U.S. Senate Agriculture Committee, noted that such a purchase calls for examining America’s overall food security. She questioned whether, if the nation’s largest pork producer could be acquired, China or other countries might next seek to purchase poultry, dairy, or corn producers. She emphasized that it would not be in America’s security interests if our food supply becomes substantially foreign owned.
In large part, the COVID pandemic set the stage for where things stand now. The initial shock of the pandemic brought dealmaking to a standstill, and with far fewer new transactions to review, CFIUS began examining older deals that had never undergone scrutiny as a way to self-educate and maintain relevance.
Grindr is a great example of this—and one of the many cases that the media has covered in depth. The gay dating app was purchased by Beijing Kunlun Tech in two transactions in 2016 and 2018. These transactions did not appear to be noticed by CFIUS until 2019, a year after the conclusion of the second transaction, when CFIUS expressed concerns about the national security risk posed by the Chinese government gaining access to the estimated 14.5 million subscribers, with the risk that some could be influenced or blackmailed due to privacy about their sexual orientation, HIV status, or because they held national security positions.
Eventually, CFIUS ordered divestment, but that did not occur until 2020. Any risk that existed was likely realized in the three-year period when the company and its data was in Chinese hands. The same could be said about U.S. security concerns related to the Chinese app TikTok, where the moment of recognizing the risk and the as-yet unknown date when the risk will be mitigated allows for any harm to be done before a remedy is in place.
CFIUS Today, and Going Forward
It is easy to see the role CFIUS plays in protecting U.S. national security by preventing malign actors from gaining access to U.S. technology or proximity to sensitive national security sites. Taking things a step further, the current Administration is keenly focused on curtailing investments that result in the outward flow of “sensitive technology, critical infrastructure, healthcare, agriculture, energy, and raw materials” to China, with specific concern about: “semiconductors, artificial intelligence, quantum computing, biotechnology, hypersonics, and aerospace.” While Administrations may take different foreign policy approaches, this has largely been a bipartisan undertaking building on historical concerns and related legislation.
China’s interest in U.S. enterprises—especially if guided with a non-financial national security purpose—are unlikely to abate. However, responding to that interest can become challenging, given legal ambiguity and flexible approaches to accessing sensitive U.S. companies and products. Simply defining what constitutes a Chinese company may seem straightforward but becomes challenging in the details. Further, there is the risk that transactions could be completed using cutouts to conceal ultimate ownership or control, not to mention other means to acquire U.S. sensitive technology outside of corporate ownership.
China is the obvious concern, but the risks from foreign access to, and control of, sensitive U.S. technology and industry is far broader. Even allies taking control of sensitive or critical U.S. companies can warrant CFIUS involvement, as arose recently with regard to Japan’s interest in acquiring U.S. Steel. Economic security has become increasingly intertwined with national security, thus any overseas engagement with U.S. companies and technology may be subject to scrutiny. National security doesn’t exist in a bubble, and each CFIUS investigation must be carefully balanced against impact to foreign direct investment and overall economic growth. Using such irregular economic capabilities provides an outlet for the U.S. Government to more discretely push back on allied interference without drumming up a public relations or diplomatic nightmare.
The opacity of the process comes with drawbacks and benefits, with the ability to transform as an efficient tool against core national security concerns as well as a viable lawfare tactic to assert influence or impose punishment. On the downside, the lack of transparency can create uncertainty for investors and businesses, chilling legitimate transactions and deterring foreign capital. At the same time, secrecy allows CFIUS to act quickly and decisively, shielding sensitive intelligence and strategic considerations from public view while neutralizing genuine threats.
This dynamic builds on the expanded mandate and resources CFIUS gained after FIRRMA and the COVID-era surge, positioning the committee as a more aggressive guardian of U.S. security interests. Adversarial strategic competition is increasingly conducted using indirect and abstract forms of influence, often flying under the radar. This has become particularly relevant in the context of rising tensions with China, where the committee’s reviews increasingly target obscure and indirect transactions tied to critical technologies, data, and infrastructure. As such, CFIUS will remain a critical instrument in the United States’ broader economic warfare toolkit, enabling strategic leverage over adversaries through control of capital and access.
Eric Lebson is the Chief Strategy Officer of the nonprofit Global Reach, where he works to help families secure the return of their loved ones. He also serves on the advisory boards of the James W. Foley Legacy Foundation and Hostage U.S. and is a member of the Commission on Hostage Taking and Wrongful Detentions at the Center for Strategic and International Studies. Eric has previously held senior roles at the Pentagon and the National Security Council.
Matthew Flug is the co-director of the Economic and Legal Warfare Project for the Irregular Warfare Initiative.
The views expressed are those of the authors and do not reflect the official position of the Irregular Warfare Initiative, Princeton University’s Empirical Studies of Conflict Project, the Modern War Institute at West Point, or the United States Government.
Main Image generated via OpenAI. DALL·E. Image generated November 16, 2025.
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