Three years into the applicability of the Foreign Subsidies Regulation (“FSR”), businesses now have a clearer basis for navigating the regime, but not all questions are answered. This alert shares key practical lessons from our experience with FSR since summer 2023: where execution risk arises, what the filing record tells us, how FSR interacts with foreign direct investment (“FDI”) screening and merger control, and what businesses can do now to make future reviews faster and…
On 24 June 2026, more than four years after the underlying events, Germany’s Federal Public Prosecutor General announced search measures in connection with a criminal investigation arising from the 2022 separation and attempted liquidation of the former German subsidiary of a major foreign state-linked energy group. What makes the case significant for FDI practitioners is straightforward: it is a forceful reminder that implementing a notifiable transaction without prior clearance is not merely a regulatory irregularity…
In Brief On 8 June 2026, the Council of the EU approved the European Parliament’s position adopted on 19 May 2026, clearing the path for a new Regulation on the screening of foreign investments in the Union (the “Screening Regulation 2026”). The Screening Regulation 2026 will repeal and replace Regulation (EU) 2019/452 (the “Former FDI Regulation”), marking a complete overhaul of the EU’s foreign investment control framework. The Screening Regulation 2026 seeks to balance security…