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CFIUS compliance: The Three Lines of Defense

Michael Rose ( is a Partner and a leader of Grant Thornton LLP’s National Governance Risk and Compliance practice in Philadelphia, Pennsylvania, USA. Steve Siemborski ( is Managing Director at Calfee Strategic Solutions in Washington, DC.

This is the third of a three-part series on complying with the new law on foreign investment in the US. In this article, we describe how a sustainable CFIUS compliance function might be established using the Three Lines of Defense model.

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