PEACE Act of 2025

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Bill ID: 119/hr/4346
Last Updated: July 17, 2026

Sponsored by

Rep. Nunn, Zachary [R-IA-3]

ID: N000193

Follow the money

The bill

PEACE Act of 2025

HR. 4346, 119th Congress — read as touching Commercial Banks.

The sponsor

Rep. Nunn, Zachary [R-IA-3]

Every bill has someone who introduced it. That name is where the paper trail starts.

The money

$142,100 raised

24 itemised contributions to this sponsor, pulled from FEC filings.

The alignment

85% match to Project 2025

This bill's text tracks the "Department of State" section, p. 214-216 of the Mandate for Leadership.

Bill's Journey to Becoming a Law

Track this bill's progress through the legislative process

Latest Action

Placed on the Union Calendar, Calendar No. 277.

October 2, 2025

Introduced

📍 Current Status

Next: The bill will be reviewed by relevant committees who will debate, amend, and vote on it.

🏛️

Committee Review

🗳️

Floor Action

✅

Passed House

🏛️

Senate Review

🎉

Passed Congress

🖊️

Presidential Action

⚖️

Became Law

📚 How does a bill become a law?

1. Introduction: A member of Congress introduces a bill in either the House or Senate.

2. Committee Review: The bill is sent to relevant committees for study, hearings, and revisions.

3. Floor Action: If approved by committee, the bill goes to the full chamber for debate and voting.

4. Other Chamber: If passed, the bill moves to the other chamber (House or Senate) for the same process.

5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.

6. Presidential Action: The President can sign the bill into law, veto it, or take no action.

7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!

Bill Summary

Another masterpiece of legislative theater, courtesy of the esteemed members of Congress. The PEACE Act of 2025 - because nothing says "peace" like a bill that's essentially a sanctions-filled Trojan horse.

**Main Purpose & Objectives:** The bill's stated goal is to secure a peaceful resolution to the Russia-Ukraine conflict by imposing strict conditions on foreign financial institutions that do business with Russia. Yeah, right. And I'm sure the President's tweets about Putin "playing with fire" had nothing to do with this bill.

**Key Provisions & Changes to Existing Law:** The bill requires the Secretary of the Treasury to prohibit or impose strict conditions on correspondent accounts and payable-through accounts held by foreign financial institutions that knowingly provide significant financial services to Russia. It also sets out penalties for non-compliance, including civil fines up to $377,700 and criminal penalties of up to 20 years in prison.

But let's get real - this bill is just a thinly veiled attempt to strong-arm Russia into submission while pretending to care about Ukraine. The "findings" section reads like a laundry list of Putin's greatest hits, carefully curated to justify the sanctions. And that waiver provision? A nice little escape clause for when the President needs to make a deal with Russia.

**Affected Parties & Stakeholders:** Foreign financial institutions, Russia, and Ukraine are the obvious players here. But let's not forget the real stakeholders: the defense contractors, arms manufacturers, and energy companies who'll benefit from this bill's inevitable escalation of tensions.

**Potential Impact & Implications:** This bill is a recipe for disaster - or at least, a nice little profit boost for the war machine. By imposing sanctions on Russia, we're essentially daring them to retaliate, which will only lead to more conflict and instability in the region. And what about the poor Ukrainian civilians caught in the crossfire? Oh wait, they're just collateral damage in our grand game of geopolitics.

In conclusion, this bill is a farce - a cynical attempt to posture as a champion of peace while actually fueling the flames of war. It's a classic case of "diplomacy by other means," where we use economic coercion to get what we want without actually doing any real diplomacy.

Diagnosis: Acute Case of Legislative Hypocrisy, with symptoms including:

* Grandstanding about peace while promoting conflict * Using sanctions as a blunt instrument to bludgeon Russia into submission * Ignoring the human cost of this bill's inevitable escalation

Treatment: A healthy dose of skepticism and a strong stomach for the hypocrisy that is Washington politics.

Generated using Llama 3.1 70B (Dr. Haus personality)

💰 Campaign Finance Network

Rep. Nunn, Zachary [R-IA-3]

Congress 119 • 2024 Election Cycle

Total Contributions
$142,100
21 donors
PACs
$0
Organizations
$10,100
Committees
$0
Individuals
$132,000

No PAC contributions found

1
SAC & FOX TRIBE OF THE MISSISSIPPI IN IOWA
2 transactions
$3,500
2
OTOE MISSOURIA TRIBE OF OKLAHOMA
1 transaction
$3,300
3
TURTLE MOUNTAIN BAND OF CHIPPEWA OF ND
1 transaction
$3,300

No committee contributions found

1
SMITH, JOHN M.
2 transactions
$13,200
2
SILVERMAN, JEFFREY
2 transactions
$13,200
3
EMMET, RICHARD
1 transaction
$6,600
4
WEEKLEY, RICHARD W.
1 transaction
$6,600
5
STERN, ELIZABETH
1 transaction
$6,600
6
RASMUSSEN, CYNTHIA
1 transaction
$6,600
7
RASMUSSEN, STEPHEN
1 transaction
$6,600
8
BELTRAME, MARC
1 transaction
$6,600
9
BRUCH, TYLER
1 transaction
$6,600
10
DANIELS, RONALD L.
1 transaction
$6,600
11
MYERS, JAMES M.
1 transaction
$6,600
12
SCHWARZMAN, CHRISTINE
1 transaction
$6,600
13
GILLIAM, RICHARD
1 transaction
$6,600
14
SINGER, PAUL
1 transaction
$6,600
15
BRADLEY, JACQUELINE
1 transaction
$6,600
16
RICKETTS, J. JOE
1 transaction
$6,600
17
UNDERWOOD, RUSS
1 transaction
$6,600
18
JONES, NORMAN
1 transaction
$6,600

Cosponsors & Their Campaign Finance

This bill has 4 cosponsors. Below are their top campaign contributors.

Rep. Gottheimer, Josh [D-NJ-5]

ID: G000583

Top Contributors

10

1
AMERICAN EXPRESS
OrganizationNEWARK, NJ
$22,941
Apr 12, 2024
2
AMERICAN EXPRESS
OrganizationNEWARK, NJ
$10,621
May 10, 2024
3
PAYROLL DATA PROCESSING
OrganizationTAMPA, FL
$6,337
May 15, 2024
4
PAYROLL DATA PROCESSING
OrganizationTAMPA, FL
$6,337
Apr 15, 2024
5
PAYROLL DATA PROCESSING
OrganizationTAMPA, FL
$6,337
Apr 30, 2024
6
PAYROLL DATA PROCESSING
OrganizationTAMPA, FL
$5,751
Apr 1, 2024
7
EASTERN BAND OF CHEROKEE INDIANS
OrganizationCHEROKEE, NC
$3,300
Oct 22, 2024
8
SEKAS LAW GROUP LLC
OrganizationENGLEWOOD CLIFFS, NJ
$1,500
Apr 12, 2024
9
SANDOR F. GENET & ASSOCIATES, P.A.
OrganizationNORTH MIAMI BEACH, FL
$250
Apr 12, 2024
10
FIRESTONE MILKEN, SARAH
NOT EMPLOYED • NOT EMPLOYED
IndividualPACIFIC PALISADES, CA
$13,200
Jul 2, 2024

Rep. Barrett, Tom [R-MI-7]

ID: B001321

Top Contributors

10

1
MICHIGAN AGGREGATES ASSOCIATION PAC
OrganizationOKEMOS, MI
$300
Feb 27, 2024
2
DEMKOWICZ, BRIAN MR.
HURON CAPITAL • INVESTOR
IndividualGROSSE POINTE, MI
$13,200
Jan 8, 2024
3
STADLER, BRIAN
WOLGAST CORPORATION • MANAGER
IndividualSAGINAW, MI
$6,870
Sep 28, 2023
4
UIHLEIN, RICHARD
ULINE • CHAIRMAN
IndividualLAKE FOREST, IL
$6,870
Sep 26, 2023
5
COURTNEY, JOHN
RETIRED • RETIRED
IndividualOKEMOS, MI
$6,870
Dec 8, 2023
6
BAKER, JEFFREY
MUSKEGON CAR CREDIT • EXECUTIVE
IndividualGRAND RAPIDS, MI
$6,600
Jul 25, 2023
7
BANCROFT, NICHOLAS
AGROLIQUID • CEO
IndividualSAINT JOHNS, MI
$6,600
Sep 19, 2023
8
HAWORTH, MATTHEW
HAWORTH, INC. • CHAIRMAN
IndividualHOLLAND, MI
$6,600
Sep 18, 2023
9
HAWORTH, RICHARD
HAWORTH, INC. • CHAIRMAN EMERITUS
IndividualSAUGATUCK, MI
$6,600
Sep 18, 2023
10
O'NEIL, WILLIAM
W J O'NEIL COMPANY • EXECUTIVE
IndividualCOMMERCE TOWNSHIP, MI
$6,600
Sep 11, 2023

Rep. Conaway, Herbert C. [D-NJ-3]

ID: C001136

Top Contributors

10

1
THE PLATT LAW GROUP P.C.
OrganizationSTRATFORD, NJ
$1,000
May 8, 2024
2
FREEHOLD TOWNSHIP DEMOCRATIC CLUB
OrganizationFREEHOLD, NJ
$250
Jul 24, 2024
3
GALLETTI, SCOTT
NOT EMPLOYED • RETIRED
IndividualHO HO KUS, NJ
$3,300
Sep 26, 2024
4
LEITNER, ROBYN
ADVANCED UROLOGIC ASSOCIATES ENTERPRIS • PHYSICIAN
IndividualPOINT PLEASANT BORO, NJ
$3,300
Jul 17, 2024
5
ESTIN, DAVID
NOT EMPLOYED • RETIRED
IndividualMONMOUTH BEACH, NJ
$3,300
Sep 26, 2024
6
SHEIKH, WASIF
ION MONITORING • NEUROPHYSIOLOGY
IndividualPISCATAWAY, NJ
$3,300
Sep 18, 2024
7
COBB, WILLIAM S
NOT EMPLOYED • RETIRED
IndividualALLENDALE, NJ
$3,300
Sep 26, 2024
8
CHAUDHRY, FARRUKH
ION MONITORING MANAGEMENT • NEUROPHYSIOLOGIST
IndividualMONMOUTH JUNCTION, NJ
$3,300
Sep 18, 2024
9
OLSON, TY J
NEUROSURGEONS OF NEW JERSEY • PHYSICIAN
IndividualRUMSON, NJ
$3,300
Sep 26, 2024
10
FALCONE, CARMEL A
NOT EMPLOYED • RETIRED
IndividualALLENDALE, NJ
$3,300
Sep 26, 2024

Rep. Suozzi, Thomas R. [D-NY-3]

ID: S001201

Top Contributors

10

1
FEDERATED INDIANS OF GRATON RANCHERIA
OrganizationROHNERT PARK, CA
$3,300
Aug 3, 2024
2
SCOTTO LLC
OrganizationWOODBURY, NY
$1,650
Aug 30, 2024
3
PATROON OPERATING CO. LLC
OrganizationNEW YORK, NY
$1,000
May 13, 2024
4
THE KLAR ORGANIZATION
OrganizationEAST MEADOW, NY
$1,000
Aug 8, 2024
5
TERIAN, OLIVIA
IndividualNEW YORK, NY
$9,400
May 2, 2024
6
TERIAN, OLIVIA
OLIVIA TERIAN ART & DESIGN • BUSINESS OWNER
IndividualNEW YORK, NY
$6,600
Mar 8, 2024
7
MORAN, MARY
NOT EMPLOYED • RETIRED
IndividualGREENWICH, CT
$6,600
Mar 28, 2024
8
MORAN, MARY
IndividualGREENWICH, CT
$6,600
May 2, 2024
9
FAIVUS, HARRY E.
MOUNT SINAI • PHYSICIAN
IndividualNEW YORK, NY
$5,000
Oct 31, 2024
10
SOSNICK, AARON
IndividualRENO, NV
$3,392
Jun 25, 2024

Donor Network - Rep. Nunn, Zachary [R-IA-3]

PACs
Organizations
Individuals
Politicians

Hub layout: Politicians in center, donors arranged by type in rings around them.

Loading...

Showing 71 nodes and 36 connections (57 secondary connections hidden)

Total contributions: $212,869

Top Donors - Rep. Nunn, Zachary [R-IA-3]

Showing top 21 donors by contribution amount

3 Orgs18 Individuals

Industry Impact

Which industries are materially affected by specific provisions in this bill. 3 harmed.

  • −Commercial Banksconfidence 0.90

    Section 3(a) requires the Secretary of the Treasury to prohibit or impose strict conditions on correspondent or payable-through accounts by foreign financial institutions that provide significant services to sanctioned Russian persons or entities in the Russian energy sector. This directly impacts U.S. commercial banks that maintain such accounts with foreign financial institutions, imposing compliance costs and potential penalties under Section 3(b).

  • Section 3(a)(4) targets foreign persons operating in the energy sector of the Russian Federation, which includes entities involved in oil and gas extraction, pipelines, and related infrastructure. This provision could restrict financial services to Russian energy infrastructure firms, affecting U.S. energy infrastructure companies that engage in cross-border transactions with Russian counterparts.

  • −Oil & Gasconfidence 0.80

    Section 3(a)(4) applies to any foreign person operating in the energy sector of the Russian Federation, which includes major Russian oil and gas producers like Gazprom, Rosneft, and Lukoil (named in Section 4). By prohibiting or conditioning correspondent accounts for institutions serving these entities, the bill restricts financial access for Russian oil and gas operations, impacting the sector globally.

Who funds the sponsor on these industries

For each industry this bill affects, here's what the sponsor (Rep. Nunn, Zachary [R-IA-3])received from donors associated with that industry during the 2022–present cycles. Donations are not proof of intent — they are a record of who funds the people writing the law.

Industries this bill HARMS

  • from 11 contributions
    • O'NEILL, EDWARD PATRICK III$2,000
    • MCCRIGHT, RANDALL J.$2,000
    • BELL, DAWN$2,000
    • BOUSTEAD, HEATHER$273
    • ONEILL, EDWARD$250
  • from 2 contributions
    • TEMPLE, RICHARD$750

Project 2025 Policy Matches

This bill shows semantic similarity to the following sections of the Project 2025 policy document.AI-enhanced analysis provides detailed alignment ratings.

Department of State

Strong
Vector: 61%
Pages: 214-216AI Enhanced

AI Analysis:

"The PEACE Act aligns with Project 2025's Department of State section by supporting continued U.S. involvement in the Ukraine conflict through economic pressure on Russia, consistent with the viewpoint advocating for U.S. engagement to defeat Putin and restore pre-invasion borders, while emphasizing fiscal responsibility and national security interests."

Key themes:Ukraine conflictRussia sanctionsU.S. national securityeconomic pressuredefeat of Putin

— 182 — Mandate for Leadership: The Conservative Promise l One school of conservative thought holds that as Moscow’s illegal war of aggression against Ukraine drags on, Russia presents major challenges to U.S. interests, as well as to peace, stability, and the post-Cold War security order in Europe. This viewpoint argues for continued U.S. involvement including military aid, economic aid, and the presence of NATO and U.S. troops if necessary. The end goal of the conflict must be the defeat of Russian President Vladimir Putin and a return to pre-invasion border lines. l Another school of conservative thought denies that U.S. Ukrainian support is in the national security interest of America at all. Ukraine is not a member of the NATO alliance and is one of the most corrupt nations in the region. European nations directly affected by the conflict should aid in the defense of Ukraine, but the U.S. should not continue its involvement. This viewpoint desires a swift end to the conflict through a negotiated settlement between Ukraine and Russia. l The tension between these competing positions has given rise to a third approach. This conservative viewpoint eschews both isolationism and interventionism. Rather, each foreign policy decision must first ask the question: What is in the interest of the American people? U.S. military engagement must clearly fall within U.S. interests; be fiscally responsible; and protect American freedom, liberty, and sovereignty, all while recognizing Communist China as the greatest threat to U.S. interests. Thus, with respect to Ukraine, continued U.S. involvement must be fully paid for; limited to military aid (while European allies address Ukraine’s economic needs); and have a clearly defined national security strategy that does not risk American lives. Regardless of viewpoints, all sides agree that Putin’s invasion of Ukraine is unjust and that the Ukrainian people have a right to defend their homeland. Furthermore, the conflict has severely weakened Putin’s military strength and provided a boost to NATO unity and its importance to European nations. The next conservative President has a generational opportunity to bring res- olution to the foreign policy tensions within the movement and chart a new path forward that recognizes Communist China as the defining threat to U.S. interests in the 21st century. The Democratic People’s Republic of Korea Peace and stability in Northeast Asia are vital interests of the United States. The Republic of Korea (South Korea) and Japan are critical allies for ensuring a free and open Indo–Pacific. They are indispensable military, economic, diplomatic, and technology partners. The Democratic People’s Republic of Korea (DPRK, or North — 183 — Department of State Korea) must be deterred from military conflict. The United States cannot permit the DPRK to remain a de facto nuclear power with the capacity to threaten the United States or its allies. This interest is both critical to the defense of the Amer- ican homeland and the future of global nonproliferation. The DPRK must not be permitted to profit from its blatant violations of international commitments or to threaten other nations with nuclear blackmail. Both interests can only be served if the U.S. disallows the DPRK’s rogue regime behavior. OTHER INTERNATIONAL ENGAGEMENTS Western Hemisphere The United States has a vested interest in a relatively united and economically prosperous Western Hemisphere. Nonetheless, the region now has an overwhelm- ing number of socialist or progressive regimes, which are at odds with the freedom and growth-oriented policies of the U.S. and other neighbors and who increasingly pose hemispheric security threats. A new approach is therefore needed, one that simultaneously allows the U.S. to re-posture in its best interests and helps regional partners enter a new century of growth and opportunity. The following core policies must be part of this new direction: l A “sovereign Mexico” policy. Mexico is currently a national security disaster. Bluntly stated, Mexico can no longer qualify as a first-world nation; it has functionally lost its sovereignty to muscular criminal cartels that effectively run the country. The current dynamic is not good for either U.S. citizens or Mexicans, and the perfect storm created by this cartel state has negative effects that are damaging the entire hemisphere. The next Administration must both adopt a posture that calls for a fully sovereign Mexico and take all steps at its disposal to support that result in as rapid a fashion as possible. l A fentanyl-free frontier. The same cartels that parasitically run Mexico are also working with the PRC to fuel the largest drug crisis in the history of North America. These Mexican cartels are working closely with Chinese fentanyl precursor chemical manufacturers, importing those precursor chemicals into Mexico, manufacturing fentanyl on Mexican soil, and shipping it into the United States and elsewhere. The highly potent narcotic is having an unprecedented lethal impact on the American citizenry. The next Administration must leverage its new insistence on a sovereign Mexico and work with other Western Hemisphere partners to halt the fentanyl crisis and put a decisive end to this unprecedented public health threat.

Department of Commerce

Moderate
Vector: 61%
Pages: 705-707AI Enhanced

AI Analysis:

"The PEACE Act of 2025 aligns with Project 2025's focus on countering Russian and Chinese economic and military threats through enhanced export controls and sanctions, particularly by targeting financial support to sanctioned entities. However, the bill centers on Treasury-led financial sanctions rather than Commerce Department-led export enforcement or EAR modernization, resulting in moderate thematic overlap but differing implementation mechanisms."

Key themes:Russia sanctionseconomic pressurenational securityexport controlsfinancial restrictions

— 673 — Department of Commerce Export Enforcement officers through improved and frequent training so they are able to detect export-control violations. EAR Revisions. The U.S. Government needs a new export control moderniza- tion effort to tighten the EAR policies governing licenses to countries of concern, including China and Russia (specifically, revise and/or reverse the 2008 through 2016 policies). When authoritarian governments explain what they plan to do, believe them unless hard evidence demonstrates otherwise. Case in point: China’s and Russia’s stated civil–military fusion policies demand central government command-and-control style systems in which every private entity serves the interests of the state and is forced to provide technology, services, capacity, and data to the central govern- ment and the military. Through this structure, commercial activities are routinely weaponized by authoritarian regimes that repeatedly identify the U.S. as an enemy. Accordingly, U.S. export control policies must be updated to reflect these realities and the associated threats to national security. Key priorities for EAR modernization for countries of concern should be: l Eliminating the “specially designed” licensing loophole; l Redesignating China and Russia to more highly prohibitive export licensing groups (country groups D or E); l Eliminating license exceptions; l Broadening foreign direct product rules; l Reducing the de minimis threshold from 25 percent to 10 percent—or 0 percent for critical technologies; l Tightening the deemed export rules to prevent technology transfer to foreign nationals from countries of concern; l Tightening the definition of “fundamental research” to address exploitation of the open U.S. university system by authoritarian governments through funding, students and researchers, and recruitment; l Eliminating license exceptions for sharing technology with controlled entities/countries through standards-setting “activities” and bodies; and l Improving regulations regarding published information for technology transfers. — 674 — Mandate for Leadership: The Conservative Promise The next few years will prove or disprove the assertion that the U.S. stands on the precipice of a Cold War with China. Many believe that a Cold War has already begun; if so, then strategic decoupling from China is necessary and, fundamentally, any exports of goods, software, and technology to countries of concern, whether directly or indirectly, should be prohibited or controlled in the absence of good cause (e.g., humanitarian and medical aid, food aid). Entity List and Sanctions. There are currently just over 500 Chinese and over 500 Russian companies on the Department of Commerce’s Entity List, which reg- ulates exports of controlled and uncontrolled items to designated entities. Given China’s Civil–Military Fusion Strategy and Russia’s massive war efforts facili- tated by a broad range of the Russian economy, BIS must add more entities to the Entity List and apply a license review “policy of denial” that prohibits exports to these entities. Entity List parties that violate export controls should be placed on the BIS Denied Persons List (and thereby lose export privileges) and, if the violations are significant enough, they should also be sanctioned by the Department of Treasury. Data Transfer and Apps Used for Surveillance. Department of Commerce leadership should work across government agencies to address privacy and data concerns arising out of “big tech” from national security and export control per- spectives. In particular, they should draft and implement an executive order (EO) based on the International Emergency Economic Powers Act, which expands export control authority beyond ECRA’s scope (goods, software, technology) to regulate and restrict exports of U.S. persons’ data to countries of concern. The EO should establish a framework for the types of personal data subject to export controls and licensing policy by country, and the BIS should implement the EO through regulations. BIS should additionally designate app providers (such as WeChat and Byte Dance/TikTok) known for undermining U.S. national security through data collection, surveillance, and influence operations, to the Entity List. This listing would prevent app users from program updates, which would quickly make these apps non-operational in the United States. NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION Break Up NOAA. The single biggest Department of Commerce agency outside of decennial census years is the National Oceanic and Atmospheric Administration, which houses the National Weather Service, National Marine Fisheries Service, and other components. NOAA garners $6.5 billion of the department’s $12 billion annual operational budget and accounts for more than half of the department’s personnel in non-decadal Census years (2021 figures). NOAA consists of six main offices: l The National Weather Service (NWS);

Department of the Treasury

Moderate
Vector: 60%
Pages: 736-738AI Enhanced

AI Analysis:

"Both the PEACE Act and the Project 2025 Treasury section seek to strengthen the Treasury Department's ability to impose financial penalties on foreign entities that support adversarial nations, emphasizing enforcement and deterrence through sanctions. However, the bill focuses on Russia-related sanctions while the Project 2025 text centers on CFIUS reforms concerning China and mitigation monitoring, resulting in only partial thematic overlap."

Key themes:Treasury enforcementfinancial sanctionsgeopolitical threatspenalty deterrencenational security

— 703 — Department of the Treasury l The U.S. should also examine increasing or decreasing its ownership levels in these institutions in order to achieve maximum leverage. CHINA AND OTHER GEOPOLITICAL THREATS Committee on Foreign Investment in the United States. The interagency Committee on Foreign Investment in the United States should realign its priorities to meet the United States’ current foreign policy threats, especially from China. On October 20, 2022, the Treasury Department, which chairs CFIUS, adopted the first-ever CFIUS Enforcement and Penalty Guidelines50 on the committee’s national security risk mitigation requirements. However, there are no clear rules that guide CFIUS on mitigation monitoring, nor is there a published penalty sched- ule to standardize accountability when CFIUS pursues a civil money penalty for violators. In addition, Treasury—as chair of the committee—runs an opaque pro- cess that biases committee procedure toward corporate interests and away from national security interests. Finally, the committee’s jurisdiction does not extend over greenfield investments that Chinese state-owned enterprises have historically pursued in the United States, which leaves America vulnerable to an instrument of Chinese economic statecraft. Given these issues, the next steps for CFIUS should be to develop a more coherent—and transparent—mitigation monitoring program to complement the enforcement guidelines, give CFIUS agencies in charge of national security con- cerns an equal voice at the table, and petition Congress to amend the law to cover Chinese greenfield investments. CFIUS should publish a penalty schedule for violations of CFIUS reporting and mitigation requirements. Publishing a penalty schedule for CFIUS violations will reduce the discretion of the committee to waive penalties or impose mere “wrist slap” costs on violators of the law. Additionally, a standardized penalty schedule would likely increase the deterrence of CFIUS enforcement by reducing the per- ception among parties to covered transactions that they can avoid enforcement by the committee or secure special exceptions based on appeals to the commit- tee’s discretion. As a legal matter—and in application by CFIUS—mitigation monitoring has developed as the Wild West. There are no clear rules that guide the entire com- mittee on mitigation monitoring, nor is there the same level of oversight or accountability within and among the agencies as applies when CFIUS reviews a transaction or when it pursues a civil money penalty. Indeed, it is a credit to transaction parties and the professionalism of the governmental officials and con- tractors who conduct mitigation monitoring on behalf of the government that, by and large, mitigation monitoring has worked adequately during the last several decades. But dependency on the personality and capabilities of individuals creates unnecessary risk both for CFIUS and for transaction parties.

Showing 3 of 5 policy matches

About These Correlations

Policy matches are calculated using a hybrid approach: initial candidates are found using semantic similarity between bill summaries and Project 2025 policy text, then an AI model (Llama 3.1 70B) provides detailed alignment ratings and analysis. Ratings range from 1 (minimal alignment) to 5 (very strong alignment). This analysis does not imply direct causation or intent.

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