The Office of the Director of National Intelligence (“ODNI”) released its 2025 Annual Threat Assessment (“ATA”) in March, providing a snapshot of how the U.S. Intelligence Community (“IC”) views global threats to the United States. Because the IC’s threat analysis is central to the risk assessment for every transaction reviewed by the Committee on Foreign Investment in the United States (“CFIUS”), the ATA is a significant source of direct insight for global investors into the CFIUS process, including how risk is perceived, what mitigation measures might be required, and when a transaction might be prohibited altogether.
Although IC leadership may change, the IC’s approach to CFIUS remains generally consistent: focused on geostrategic competition with China and the intersection of economic and national security.
Below, we analyze what the 2025 ATA can tell us about CFIUS’s view of the global threat landscape, how it might change (or not) under new IC leadership, and lay out key takeaways for global investors.
I. Understanding the IC’s Role in the CFIUS Process
The IC is not a voting member of CFIUS, meaning it does not take a view on what the outcome of the CFIUS review should be, but it sets the table for all CFIUS decisions by producing a threat assessment for each notified transaction. This assessment takes the form of either a full National Security Threat Assessment (“NSTA”) or a shorter Basic Threat Information memorandum. A threat assessment, developed under the leadership of ODNI, incorporates collection and analysis from across the many IC members across the U.S. government. It provides CFIUS with the IC’s assessment of the intent and capability of the foreign investor (or a relevant third-party threat actor) to harm the national security of the United States.
CFIUS then produces its holistic risk assessment of the transaction by combining (i) the IC’s assessment of the threat with (ii) its own assessment of the vulnerabilities of the U.S. business and the (iii) consequence of the threat actor(s) exploiting the U.S. business’ vulnerabilities.
II. Significant Continuity in How the IC Views Economic Security Issues
Given the significant changes in leadership at ODNI and throughout the IC, the 2025 ATA is notable for its continuity in the areas most relevant to CFIUS. Though much attention was paid to the ATA’s prominent listing of threat from foreign illicit drug actors, the core threats and analytic framing applicable to CFIUS remain largely unchanged from 2024. This consistency is reflected in the following topics:
- China remains the central concern. The 2025 ATA reaffirms that China is the “most comprehensive and robust” strategic competitor to the United States. Like the 2024 report, it highlights China’s ambition to dominate strategic sectors including AI, semiconductors, biotech, and quantum computing—precisely the types of technologies that often trigger CFIUS concerns. However, unlike the 2024 report, this year’s report adds references to China’s manufacturing subsidies, steel, “cheap Chinese exports”, and China’s trade surplus.
- The 2025 ATA specifically warns that China is exploring conventional intercontinental-range missile systems and enhancing its cyber capabilities, which could be employed against U.S. infrastructure in the event of a conflict.
- These concerns echo the IC’s consistent concern that China is leveraging “whole-of-government” campaigns to compel compliance with its preferences globally, including through economic, military, and technological tools.
- The report signals continued sensitivity towards Chinese integration in critical U.S. supply chains, including those that do not necessarily trigger a mandatory filing.
- Technology and economic security are central themes. The 2025 ATA emphasizes the growing overlap between national security and economic competitiveness, as also reflected in Trump’s America First Investment Policy. Specifically, the IC warns of adversaries’ efforts to erode U.S. leadership in key technological sectors and weaponize supply chain dependencies. The focus on the PRC’s efforts to “fend off challenges to its legitimacy” and gain an edge in economic and military power remains consistent with 2024.
- Cyber threats and data vulnerabilities are enduring concerns. The 2025 ATA again identifies China as the most persistent cyber threat and highlights Beijing’s ability to compromise U.S. infrastructure. This reinforces ongoing CFIUS concerns over foreign access to sensitive personal data and critical infrastructure—a throughline from 2024’s report.
- Cooperation among adversaries is a growing concern. A new emphasis in the 2025 report is the growing cooperation among U.S. adversaries, including China, Russia, Iran, and North Korea. While not inconsistent with the 2024 report, this signals that CFIUS may increasingly assess threat in a networked way—not just what a foreign investor might do on its own, but how its allies or partners might benefit.
III. Key Takeaways for Global Investors
- Analytic continuity during a time of turbulence. The IC’s worldview as reflected in the 2025 ATA will be familiar to investors who have gone through the CFIUS process in the last several years: China is the priority threat; critical technologies and infrastructure are the front lines; and economic security is national security.
- China ties are a persistent red flag. The IC will continue to inform CFIUS that investment from China—regardless of whether the investor is private or state-owned—can be a potential instrument of Chinese statecraft. Moreover, non-Chinese investors should continue to expect scrutiny if they have meaningful business, R&D, or financing connections to China.
- Expect a broad interpretation of national security. The IC has been a primary driver of the CFIUS’s expanding conception of national security, which now run the gamut from technology transfer via civil-military fusion to exploitation of genomic data for intelligence operations. The 2025 ATA underscores that this already broad conception is likely to continue to expand as the IC identifies new threat vectors and catalogs evolving adversary tactics.
- Read the ATA like a roadmap. Understanding the IC’s public assessments can help anticipate concerns, inform drafting of transaction agreements and filings, shape mitigation proposals, and avoid surprises during review.
- Continued integrations of trade and national security concerns. The threat assessment reflects the Administration view, as spelled out in the America First Investment Policy directive, that “economic security is national security.” In practice, CFIUS may increasingly conduct its national security assessment to reflect concerns that historically have been considered purely trade in nature and, therefore, beyond CFIUS’s remit.
The IC will continue to play a crucial role shaping how CFIUS thinks about risk. Although the ATA is merely the unclassified tip of the intelligence iceberg, it can nonetheless serve as a basic guide for understanding (a) the concerns the CFIUS might identify in a transaction and (b) which transaction should be referred to CFIUS counsel for a thorough risk analysis.
