This update reviews material U.S. legal and regulatory developments as of September 19, 2026.

The Committee on Foreign Investment in the United States released its 2025 Annual Report to Congress on September 18. Key findings include a 12% increase in total filings compared to 2024, with 412 notices and declarations filed. Technology, critical infrastructure, and sensitive personal data sectors accounted for 68% of all filings. Transactions involving acquirers from China, the UAE, and Türkiye represented the three largest country-of-origin categories by filing volume.

The report notes that CFIUS completed 23 investigations in 2025, resulting in 8 mitigation agreements and 4 presidential prohibitions. The average review period for notices was 47 days, and the average investigation period was 89 days.

The inclusion of Türkiye in the top three country-of-origin categories reflects the growing volume of Turkish outbound M&A into the United States. Turkish acquirers should expect heightened CFIUS scrutiny, particularly for transactions involving technology, defense supply chain, critical infrastructure, or sensitive personal data. The report's emphasis on mitigation agreements as a preferred outcome — rather than prohibition — suggests that well-structured voluntary filings with proactive mitigation proposals can achieve favorable outcomes even in sensitive sectors.

The Internal Revenue Service issued updated enforcement guidance on Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business, on September 17. The guidance clarifies the penalty structure for late or incomplete filings and announces an enhanced matching program that cross-references Form 5472 data with customs import records, bank account information returns, and FBAR filings.

Turkish companies with U.S. subsidiaries or branches must file Form 5472 for each reportable transaction with related foreign parties. The enhanced matching program significantly increases the risk of detection for unreported or underreported related-party transactions. Turkish parent companies should review their U.S. subsidiaries' Form 5472 compliance, particularly for intercompany loans, management fees, royalties, and cost-sharing arrangements that may not have been consistently reported.

The Department of Labor's final rule updating the salary threshold for overtime exemption under the Fair Labor Standards Act took effect on September 15. The new threshold is $1,128 per week ($58,656 annually) for the executive, administrative, and professional exemptions, and $151,164 annually for the highly compensated employee exemption.

Turkish companies with U.S. employees should review their workforce classifications against the new thresholds. Employees previously classified as exempt who fall below the new salary threshold must either receive a salary increase to maintain exempt status or be reclassified as non-exempt and become eligible for overtime pay.

The Department of Commerce issued the final affirmative determination in the antidumping investigation of large diameter welded pipe from Türkiye on September 18. The final dumping margins are 18.7% for Borusan Mannesmann, 12.4% for Tosçelik, and 15.1% for all other Turkish producers.

U.S. importers of Turkish large diameter welded pipe should adjust their cost models to reflect the final dumping margins. Turkish producers should review their pricing and cost structures to assess whether the margins can be reduced in future administrative reviews. The final determination will be published in the Federal Register and will become effective upon publication of the International Trade Commission's final injury determination.

This publication is for general informational purposes only and does not constitute legal advice.