As FDI screening regimes expand globally, investors increasingly face a fragmented regulatory landscape. While the U.S, the UK and nearly all EU Member States have introduced or updated FDI controls, there is little harmonisation in processes, timelines, or sectoral scope. This creates significant challenges for cross-border transactions, especially in strategic sectors such as energy, defence, and emerging technologies.

With more deals triggering multi-jurisdictional filings, navigating simultaneous notification processes and aligning regulatory timelines has become a critical component of transaction planning. Investors must also be prepared for the growing use of conditional approvals and national security remedies - ranging from governance restrictions and data access limitations to operational guarantees and divestiture requirements. At the same time, a large portion of FDI scrutiny involves transactions between allied countries, such as U.S–EU deals, raising questions about whether existing resources are being optimally allocated.