Mexico’s New National-Security Screening Regime for Foreign Investment

Origins, Mechanics, and a Comparative Look at Canada, the United States, and the European Union

>49%

ownership triggers a mandatory pre-closing review

6

named categories of “sensitive sectors”

60

business days for CNIE to decide

US$1.4M

fine for closing without clearance

I. Executive Summary

On August 28, 2026, President Claudia Sheinbaum's administration submitted a bill to the Mexican Senate that would add a new Title to Mexico's 1993 Foreign Investment Law, creating for the first time a dedicated, procedurally defined national-security review of inbound foreign investment. The reform would require foreign investors acquiring more than 49% of the capital stock of a Mexican company in a broadly defined set of "sensitive sectors" to obtain pre-closing clearance from the National Foreign Investment Commission (CNIE), now reconstituted to include the Army, Navy, and federal public-security authorities as voting members. Closing without clearance would render the transaction legally ineffective in Mexico and expose the parties to fines of roughly US$1.4 million.

This is a genuine break from four decades of Mexican practice. Since the 1993 Foreign Investment Law replaced a far more restrictive predecessor, Mexico's default posture toward foreign capital has been open-door: FDI has generally required no prior authorization at all, and the handful of sector caps that do exist (broadcasting, land transport, agriculture, and a few others) have been administered by an economically oriented interagency commission with only nominal, undefined security authority. The bill now before the Senate would, for the first time, treat inbound capital as a standing national-security variable — the posture the United States has held since 1988, and one Canada and the European Union have progressively built out over the past four to six years.

This briefing (1) summarizes the bill's mechanics and its unresolved gaps, (2) explains the political and economic context that produced it now — principally the 2026 USMCA joint review, direct U.S. legislative pressure to close what Washington regards as a Chinese transshipment loophole, and a domestic reckoning with a slowdown in genuinely new, as opposed to reinvested, foreign capital — and (3) compares the proposed CNIE regime with the analogous frameworks in Canada, the United States, and the European Union, each of which arrived at broadly similar screening logic by a different institutional path. It closes with practical implications for foreign buyers and their advisors.

II. What the Bill Does

A. The trigger and the covered sectors

Under the current Foreign Investment Law, CNIE’s role is principally economic: it approves foreign ownership above statutory caps in a short list of reserved sectors (broadcasting, land transport, agriculture, aviation, and a few others) by weighing employment, technology transfer, and competitive effects, with national security appearing only as a vague, undefined, and “impractical” secondary factor under the law’s Article 30. Silence after 45 business days currently means a deal is deemed approved.

The proposed amendment layers an entirely new, freestanding filing obligation on top of that regime. Mandatory pre-closing CNIE authorization would be required whenever a foreign investor acquires, directly or indirectly, more than 49% of the capital stock of a Mexican company that both (a) operates in a “covered sector” and (b) exceeds an asset-value threshold CNIE itself must set within 180 calendar days of the law’s publication. Until CNIE publishes that threshold, the regime’s real-world reach is impossible to size precisely — every law-firm alert reviewed for this briefing flags the same transitional gap.

The covered sectors, as described in the bill, fall into six groups:

Strategic infrastructure — energy, transport, healthcare, communications, mining, data processing and storage, digital systems, aerospace, defense, and land or buildings essential to that infrastructure;
Critical and dual-use technology — artificial intelligence, robotics, semiconductors, cybersecurity, quantum computing, nuclear technology, nanotechnology, biotechnology, and energy storage;
Fundamental inputs — energy, raw materials, and food security;
Sensitive information, including personal data; and
A catch-all for any other sector CNIE designates by general resolution as “analogous.”

Investors below the 49% threshold, or below whatever asset value CNIE eventually sets, may still file voluntarily for legal certainty.

B. The process — and the single most consequential change

CNIE would have 60 business days to decide, with one permitted suspension to request additional information and one further 30-day extension. The critical design choice is what happens if CNIE simply does nothing: under the current law, silence means approval; under Título Sexto Bis, silence means denial. Reversing that default — from “deemed approved” to “deemed denied” — is arguably a bigger change to Mexico’s investment climate than the sectoral list itself, because it shifts the cost of bureaucratic delay from the state onto the investor in every close case.

Existing foreign-owned businesses are not retroactively swept in merely by virtue of having closed before the law takes effect, but the exemption is narrow: increased stakes, sales between foreign investors, bolt-on acquisitions, and upstream reorganizations of an existing Mexican operation would all appear to be treated as new, reviewable transactions. Nor is there any carve-out for USMCA treaty partners — Canadian and U.S. investors get no presumptive exemption from filing.

Two significant questions remain genuinely open in the public record as of this writing: whether the law provides any administrative appeal or judicial review path distinct from Mexico’s general amparo framework, and how the regime intersects with the fideicomiso structure foreign buyers use to hold real estate in Mexico’s restricted coastal and border zones.

III. Why Now: The Political and Economic Backdrop

A. The USMCA joint review is the immediate trigger

The bill did not appear in isolation. The USMCA’s mandatory joint review formally opened July 1, 2026, and U.S. Trade Representative Jamieson Greer stated plainly that Washington would not simply renew the agreement in its current form. The Center for Strategic and International Studies’ own USMCA review analysis noted, in the months before the bill was filed, that “Mexico has yet to establish a comparable national security review framework, despite promising the Biden administration that it would stand up a comparable institution,” and floated a coordinated regional screening mechanism as a natural outcome of the review. Mexico’s own explanatory text accompanying the bill cites the United States (CFIUS), Canada (the Investment Canada Act, as expanded in 2025 to include “economic security” factors), and OECD practice as the model it is converging toward — and Mexican financial press covered the story under headlines to the effect of “Mexico moves toward greater scrutiny of foreign investment for national security, in line with the U.S.” The timing — submitted days before the fourth round of bilateral USMCA negotiations — was not a coincidence.

The pressure has a specific legislative expression in Washington. Senators Dave McCormick and Catherine Cortez Masto introduced the bipartisan “Protecting the USMCA from Harmful Chinese Investment Act” in 2025, which would make it a formal U.S. negotiating objective in the 2026 review that Mexico and Canada each stand up a CFIUS-style screening framework and coordinate with the U.S. through a trilateral mechanism. The bill’s own findings state that Mexico currently lacks any comprehensive national-security FDI regime and that Chinese firms have deepened their footprint in Mexican supply chains, particularly telecommunications — and that the Mexican government had “expressed openness” to building exactly the kind of framework now before its Senate.

B. The China transshipment problem is concrete, not theoretical

The proximate policy concern is Chinese capital and Chinese-origin goods using Mexico as a bridge into the U.S. market under USMCA preferences. The U.S. Office of Trade and Manufacturing Policy has estimated that $67 billion in goods bound for the United States were transshipped through China via Mexico, India, and Vietnam in 2025. Mexico’s own textile industry made a parallel domestic case: after port crackdowns at Manzanillo and Lázaro Cárdenas closed off direct smuggling routes, the industry chamber Canaintex alleges Chinese merchandise is now being triangulated through third countries, with seven in ten garments sold in Mexican street markets allegedly now of illicit origin — a claimed 150 billion peso (roughly US$8.8 billion) annual cost.

Congress had already responded on the tariff side in December 2025, raising duties on non-FTA countries (in practice, principally China) across autos (up to 50%), auto parts, steel, textiles, plastics, furniture, cosmetics, and appliances — more than 1,000 tariff lines in total, framed as a “Program for the Protection of Strategic Industries.” Título Sexto Bis is the ownership-side complement to that trade-side response: where the tariff package addresses goods crossing the border, the investment-screening bill addresses capital crossing it.

The most-watched test case in the sector — Chinese EV maker BYD’s planned Mexico assembly plant — is a useful, if slightly counter-intuitive, data point. Reporting from the Financial Times indicates it was Chinese authorities, not Mexican ones, who withheld approval for the plant, reportedly over concern that Mexico could become a technology-leakage risk or a backdoor for Chinese EVs into the U.S. market amid Trump-era tariff threats; BYD ultimately shelved the project. No public reporting identifies an instance of Mexico’s CNIE having blocked a Chinese acquisition under current law — this bill is the first concrete step toward being able to.

C. A parallel financial-integrity thread

There is a second, quieter thread behind the bill: concern about dirty money moving through Mexico’s financial system. In mid-2025, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) took an unprecedented step, issuing its first-ever orders under the FEND Off Fentanyl Act against three Mexican financial institutions — CIBanco, Intercam Banco, and Vector Casa de Bolsa. Treasury declared all three of “primary money laundering concern,” alleging they had laundered cartel proceeds and helped pay for fentanyl-precursor chemicals sourced from China. Mexico’s own 2026 National Drug Control Strategy picked up the same thread, stating that identifying money-laundering operations — “particularly those involving Chinese operators” — is now a mandatory area of cooperation with Washington, not an optional one.

We could not find any reliable source pointing to one specific cartel-linked business acquisition that triggered the bill. But the bill’s own stated reference points make clear this concern shaped its drafting: Mexico’s 2025–2030 National Development Plan lists transnational organized crime, money laundering, and terrorism financing as national-security threats, and a December 2023 memorandum between the U.S. and Mexico already committed both governments to a joint working group on investment review, built around OECD principles. Put together, these threads show that illicit finance is a second, standing rationale for the bill — sitting alongside, not replacing, the China-trade concerns described above.

D. The domestic data problem gives the bill a second audience

There is also a purely domestic argument for the bill, and it cuts in an interesting direction for anything built from this briefing. Sheinbaum’s September 1 annual address touted record first-half 2026 FDI of roughly $35 billion. But the composition of that figure tells a less flattering story: new capital was only about 7.8% of the total, with reinvested profits making up nearly 89%; fresh investment fell 13% year over year, and one Mexican outlet reported new (non-reinvested) investment down more than 51% year over year in the same period — the lowest quarterly figure since 2014. Greenfield investment specifically is down nearly 50% since 2025. Multiple auto-parts manufacturers in Aguascalientes are reportedly now evaluating relocation to Vietnam. Analysts quoted in the Mexican press — including Gabriela Siller Pagaza of Banco Base and Adriana García of México ¿Cómo Vamos? — have warned that the bill’s genuinely ambiguous drafting could add regulatory uncertainty at precisely the moment new capital formation is already weak, and Siller explicitly linked the bill’s timing to the Trump administration’s broader China-containment strategy. In short: the same bill Mexico is offering the U.S. as evidence of seriousness on security is landing in a domestic investment climate that was already softening before the bill existed — a tension worth naming plainly rather than glossing over.

E. The through-line

Read together, these threads describe a single dynamic: Mexico is trading a fixed cost — friction on a defined slice of future foreign transactions, mostly in sectors far removed from the small and mid-market operating businesses foreign buyers most often pursue — for a strategic asset it needs regardless of who occupies the White House after 2028: continued preferential access to the U.S. market under USMCA, and a credible answer to the charge that it is a back door for Chinese capital and goods. That trade only makes sense, from Mexico’s perspective, if the screening regime stays narrow enough in practice not to deter the broader base of North American and European buyers Mexico still very much wants. Whether CNIE’s eventual implementing rules honor that intent, or whether the “analogous sectors” catch-all and the deemed-denial default end up chilling deals well outside the bill’s stated targets, is the open question every foreign investor’s counsel will be watching over the next twelve months.

IV. How Mexico’s Proposal Compares

T H E T R I G G E R , SI D E B Y SI D E

MEXICO

TRIGGER
Bright line: more than 49% ownership

PRE-CLOSING FILING
Mandatory for every deal that meets it

DECIDED BY
CNIE, now including the Army, Navy and public-security authorities

CANADA

TRIGGER
No fixed percentage; net-benefit review above set thresholds

PRE-CLOSING FILING
Not yet mandatory

DECIDED BY
Minister of Innovation, Science and Industry

UNITED STATES

TRIGGER
No fixed percentage; turns on control and access rights

PRE-CLOSING FILING
Only for a narrow mandatory category

DECIDED BY
CFIUS — nine voting departments

EUROPEAN UNION

TRIGGER
No EU-wide percentage; each member state sets its own

PRE-CLOSING FILING
Mandatory EU-wide under the reform

DECIDED BY
Each member state’s own authority

Mexico would be the only one of the four to hang the whole regime on a fixed ownership percentage. The full comparison, including timelines and penalties, is in the table at the end of section IV.

A. Canada — a discretionary, threat-based model with no ownership bright line

Canada’s Investment Canada Act runs two entirely separate tracks. A “net benefit” review, above indexed monetary thresholds that in 2026 range from C$5 million (non-WTO investors, asset value) up to C$1.452 billion (ordinary WTO private investors, enterprise value), asks a purely economic question — is the investment likely to benefit Canada — and is decided by the Minister of Innovation, Science and Industry. A separate national security review, with no dollar floor at all, can reach any investment, controlling or not, including asset- and IP-only deals since 2024 amendments (Bill C-34) closed that gap. There is no fixed ownership percentage that triggers Canadian security review the way Mexico’s bill uses 49%; instead, Canada assesses twelve guideline factors — including a new “economic security” factor added in 2025 — against a published Sensitive Technology List covering eleven domains from artificial intelligence to quantum computing to advanced materials. The statutory clock, if fully extended through Cabinet referral, can run to roughly 200 days, though the government’s own 2024–25 annual report shows an average extended review of 155 days, and a mandatory pre-closing filing requirement for defined “prescribed businesses” — the provision that would be Canada’s closest analogue to Mexico’s bright-line approach — remains in draft regulation, not yet in force, as of early 2026.

Canada has, however, used its existing tools aggressively against one specific class of investor: state-owned or state-linked enterprises seeking control of Canadian critical-minerals companies, which the government has said will be approved only “on an exceptional basis,” and under which it ordered three Chinese companies to divest lithium-sector holdings in November 2022. The 2025 U.S. legislative record — the same McCormick–Cortez Masto bill referenced above — explicitly holds Canada out as the USMCA partner that already has a comparable framework, leaving Mexico as the outlier the bill is designed to correct.

B. The United States — sector- and rights-based jurisdiction, not an ownership percentage

CFIUS, the oldest and most developed of the three comparators, does not use an ownership-percentage trigger either. Its jurisdiction turns on whether a transaction confers “control” (assessed functionally, not by a fixed percentage) over any U.S. business, or whether a non-controlling investment in a business handling critical Technology, Infrastructure, or sensitive Data (a “TID US business”) gives the foreign investor board access, access to material non-public technical information, or influence over decisions involving that technology, infrastructure, or data. Mandatory filing — as opposed to CFIUS’s much broader voluntary jurisdiction — attaches only where a TID business is involved and either a foreign-government ownership test or a critical-technology export-license test is met: a narrower, more surgical trigger than Mexico’s blanket 49%-plus-sector approach, but one that can also reach minority stakes Mexico’s bright-line rule would not touch.

CFIUS review runs 45 days initially, up to another 45 in investigation, plus a possible 15-day extension and a 15-day presidential decision window if referred — comparable in overall order of magnitude to Mexico’s 60 business days, though CFIUS’s 2025 annual data shows average processing of about 83 days and a rising share of cases pushed into the longer track, with China and Hong Kong the single largest source of long-form filings. Committee composition is a genuine point of contrast: CFIUS is chaired by Treasury, a civilian economic ministry, operating by interagency consensus among nine voting departments, with only the President holding ultimate block authority — a structure that separates the investigative function from the veto in a way Mexico’s bill, which folds the Army, Navy, and Public Security directly into CNIE’s voting membership, does not. The clearest analogue to Mexico’s food-security category is the U.S. Secretary of Agriculture’s 2024 addition to CFIUS specifically for agricultural-land and agri-biotech deals — a sector-specific carve-out, not the general security-agency presence Mexico’s bill contemplates across every covered sector. Since February 2025, the Trump administration’s “America First Investment Policy” has pushed CFIUS further toward exactly the posture Mexico is now adopting: fast-tracking allied capital while sharply tightening scrutiny of “foreign adversary” investment, seeking new authority to reach greenfield projects CFIUS cannot currently touch, and moving away from negotiated mitigation agreements toward outright blocking — only 9% of 2024 notices cleared with mitigation, down from 23% two years earlier.

C. The European Union — no single trigger, twenty-seven regimes loosely coordinated

The EU offers the least useful direct analogue and the most useful cautionary example. Regulation (EU) 2019/452 does not create a European screening authority at all; it obliges member states that screen an investment to notify Brussels and their peers, who have narrow windows to comment, and lets the European Commission issue an opinion — but the reviewing state retains the final decision, and the Commission cannot override it. Twenty-five of the EU’s twenty-seven member states currently have their own national regimes (Cyprus’s took effect in April 2026; Croatia’s is not yet fully operational), and thresholds vary enormously by country: Germany screens at 10%, 20%, or 25% depending on sector; France generally at 25% (10% for listed companies); Italy, under its “Golden Power” law, at tiers from as low as 3% up to 50% depending on sector and deal value.

A reform adopted by the European Parliament and Council in mid-2026 will eventually make national screening mandatory EU-wide and impose a common minimum sectoral floor and a harmonized 45-day first-phase clock, closing a loophole the EU’s top court exposed in 2023 when it held that an EU-incorporated subsidiary of a non-EU parent fell outside the existing regulation’s scope entirely — but that reform will not become applicable on the ground until roughly 2028, and even then, no EU-wide ownership percentage is contemplated; each member state keeps setting its own. Germany’s blocked 2022 sale of an Elmos Semiconductor chip plant to a Chinese-linked Swedish buyer, and its blocked sale of MAN Energy Solutions’ gas-turbine unit to a Chinese state shipbuilder, are the closest European precedents to what Mexico’s bill is trying to pre-empt in advance rather than police after the fact. The Netherlands’ emergency seizure of control over Chinese-owned chipmaker Nexperia in September 2025 — accomplished not through an FDI-screening statute at all, since the underlying 2019 acquisition predated the Netherlands having one, but through an emergency goods-availability law — is a pointed illustration of the gap Mexico’s bill is trying to close prospectively: a screening regime only works on deals that have not yet closed.

D. Comparative summary

The table below lines up the four regimes across the dimensions that matter most for deal planning.

DIMENSION

Penalty for closing without clearance

MEXICO (PROPOSED)

Fine of roughly US$1.4 million; transaction rendered legally ineffective in Mexico

CANADA
(ICA)

Up to C$25,000/day for general contravention; up to C$500,000 for a missed mandatory filing (once in force); Cabinet-ordered unwind or divestiture

UNITED STATES (CFIUS)

Up to $5 million per violation (2024 rule); presidential unwind/divestment order; no penalty yet issued specifically for a failure to file

UNITED STATES (CFIUS)

France: deal void, fines up to 2x deal value / 10% of turnover / €1–5M, up to 5 years’ imprisonment. Germany: retroactive unwind via trustee. Italy: voting-rights freeze

Treatment of China / SOE investment

Not formally differentiated in the bill text; the sector list and security- agency role functionally target China-origin risk

Materially harsher: asset-value (not enterprise-value) thresholds for SOEs; critical-minerals control by foreign SOEs approved only “on an exceptional basis”

“America First Investment Policy” (Feb. 2025) fast-tracks allied capital while sharply tightening review of “foreign adversary” (China, Russia, Iran, North Korea) investment

No EU-wide SOE rule. China was 9% of 2024 screening notifications, up 50% y/y; individual states (Germany) have blocked specific Chinese deals

Treatment of USMCA / allied investors

filing None. USMCA partners receive no exemption from filing

investors Higher, enterprise-value thresholds for trade-agreement investors versus non-WTO/SOE investors

New Zealand “Excepted investor” exemption from FIRRMA’s expanded jurisdiction for Australia, Canada, the UK, and New Zealand

No blanket exemption; intra-EU investment by EU subsidiaries of non-EU parents is being newly brought within scope

V. Practical Implications for Foreign Buyers

For Canadian, U.S., and international entrepreneurs acquiring existing Mexican operating businesses, four points are worth flagging now, well before CNIE’s implementing rules are published.

First, structure matters more than it used to. A transaction structured to leave the foreign acquirer at or below 49% of capital stock — a joint venture, a staged earn-in, or a minority-plus-governance-rights structure — would, on the bill’s current wording, sit outside the mandatory filing trigger entirely, unlike the U.S. and Canadian regimes, which can reach minority and non-controlling stakes through rights-based tests. That is a genuine planning opportunity while the bright-line 49% test remains the operative standard, though it is worth building in flexibility in case CNIE’s regulations narrow it later.

Second, sector matters more than deal size, at least until CNIE publishes its asset threshold. The businesses most exposed are those touching the enumerated categories — telecom and digital infrastructure, energy and raw materials, transportation and logistics infrastructure, food and agricultural supply chains, data-handling businesses of any kind, and anything with an AI, semiconductor, or cybersecurity component. Most small and mid-market operating businesses in professional services, consumer, hospitality, light manufacturing outside those categories, and traditional retail are unlikely to be touched at all.

Third, timing discipline now has real teeth. The reversal from “deemed approved” to “deemed denied” means a deal that falls within scope and stalls in CNIE’s process — whether from bureaucratic backlog, an information request, or a discretionary extension — defaults to failure rather than success. Deal timelines and closing mechanics for any transaction with plausible sectoral exposure should build in real CNIE lead time from the outset, and letters of intent signed before the law is enacted, in transactions capable of closing quickly, may be worth accelerating.

Fourth, no USMCA carve-out should be assumed. Canadian and U.S. buyers do not get preferential treatment under the bill as drafted, unlike the exemptions the U.S. affords Canada, the UK, Australia, and New Zealand under CFIUS’s “excepted investor” rules. That is a meaningful asymmetry that a Canadian buyer in particular should understand going in: Mexico is not mirroring the allied fast-track that Washington itself has built for them.

VI. Outlook

The bill has a clear political tailwind — a presidential initiative from a party with majorities in both chambers of Congress, filed to strengthen Mexico's hand in a trade negotiation it needs to win — and no organized public opposition has yet surfaced from Mexico's main business chambers or opposition parties in the reporting reviewed for this briefing, though the bill is barely a week old as of this writing and that may well change once committee hearings begin. The most consequential unknowns are entirely in CNIE's hands: where it sets the asset-value threshold, how expansively it uses the "analogous sectors" catch-all, and whether it builds a genuine appeal mechanism into its implementing regulations. Those three choices, more than the statute's headline structure, will determine whether Mexico ends up with a narrowly targeted, CFIUS-style gate on a defined slice of strategic transactions — the outcome its own public messaging promises — or a broader source of friction that catches deals well outside its stated purpose. For now, the most useful advice is not to defer transactions on account of the bill, but to build sectoral and structural diligence for it into every new mandate starting today.

Follow us for further updates on the amendments as it navigates the review process and until it's adopted.

Sources

Mexico — Título Sexto Bis

Holland & Knight, “Mexico Proposes National Security Review Regime for Foreign Investment,” Sept. 1, 2026 — https://www.hklaw.com/en/insights/publications/2026/09/mexico-proposes-national-security-review-regime-for-foreign-investment
White & Case, “Mexico FDI: President Sheinbaum Proposes National Security Screening of Foreign Investment,” Sept. 2, 2026 — https://www.whitecase.com/insight-alert/mexico-fdi-president-sheinbaum-proposes-national-security-screening-foreign
White & Case, “Foreign Direct Investment Reviews 2026: Mexico” — https://www.whitecase.com/insight-our-thinking/foreign-direct-investment-reviews-2026-mexico
CLM, “Mexico’s President Sheinbaum Proposes National Security Screening of Foreign Investment” — https://www.clm.com/mexicos-president-sheinbaum-proposes-national-security-screening-of-foreign-investment/
Basham, “México propone un nuevo régimen de revisión de inversiones extranjeras por razones de seguridad nacional” — https://basham.com.mx/mexico-propone-un-nuevo-regimen-de-revision-de-inversiones-extranjeras-por-razones-de-seguridad-nacional/
hlc.com, “Mexico wants to screen foreign takeovers for national security” — https://www.hlc.com/en/publications/mexico-wants-to-screen-foreign-takeovers-for-national-security-heres-what-you-need-to-know
Rio Times, “Mexico Foreign Investment Screening Bill Puts Security Chiefs at the Table” — https://www.riotimesonline.com/mexico-foreign-investment-screening-textiles-china-2026/
Bloomberg Línea, “México va por mayor escrutinio a inversión extranjera por seguridad nacional, en línea con EEUU,” Sept. 1, 2026 — https://www.bloomberglinea.com/latinoamerica/mexico/mexico-va-por-mayor-escrutinio-a-inversion-extranjera-por-seguridad-nacional-en-linea-con-eeuu/
Expansión, “Reforma de Sheinbaum propone poner lupa en inversión extranjera,” Aug. 31, 2026 — https://expansion.mx/economia/2026/08/31/mexico-revision-inversion-extranjera-seguridad-tmec
La Razón, “Reforma a la Ley de IED pone en duda llegada de nuevos capitales,” Sept. 1, 2026 — https://www.razon.com.mx/negocios/2026/09/01/reforma-a-la-ley-de-ied-pone-en-duda-llegada-de-nuevos-capitales/
El Universal, “Senado recibe iniciativa presidencial de reforma a Ley de Inversión Extranjera” — https://www.eluniversal.com.mx/nacion/senado-recibe-iniciativa-presidencial-de-reforma-a-ley-de-inversion-extranjera-propone-nuevo-filtro-de-seguridad-nacional/
Mexico Business News, “Mexico Moves to Screen Foreign Investment for National Security” — https://mexicobusiness.news/trade-and-investment/news/mexico-moves-screen-foreign-investment-national-security
Mexico Business News, “FDI Capital Grows Cautious; Mexico Awaits Clarity on USMCA,” Sept. 1, 2026 — https://mexicobusiness.news/trade-and-investment/news/fdi-capital-grows-cautious-mexico-awaits-clarity-usmca
Mexico News Daily, “In second annual report to the nation, Sheinbaum hails a stronger, more prosperous Mexico,” Sept. 1, 2026 — https://mexiconewsdaily.com/news/second-annual-report-sheinbaum-stronger-mexico/

USMCA / U.S. Policy Context

CSIS, “USMCA Review 2026” — https://www.csis.org/analysis/usmca-review-2026
CSIS, “Harmonizing Inbound Investment Screening” — https://www.csis.org/analysis/harmonizing-inbound-investment-screening
USTR, “Ambassador Greer Issues Statement on USMCA Joint Review,” July 1, 2026 — https://ustr.gov/about/policy-offices/press-office/press-releases/2026/july/ambassador-greer-issues-statement-usmca-joint-review
Sen. Dave McCormick, “Senators McCormick and Cortez Masto Introduce Legislation to Protect the USMCA from Harmful Chinese Investment” — https://www.mccormick.senate.gov/news/press-releases/senators-mccormick-and-cortez-masto-introduce-legislation-to-protect-the-usmca-from-harmful-chinese-investment/
East Asia Forum, “Mexico’s protectionist shift can lock in the US-Mexico-China triangle,” Dec. 19, 2025 — https://eastasiaforum.org/2025/12/19/mexicos-protectionist-shift-can-lock-in-the-us-mexico-china-triangle/
Mexico News Daily, “FT: BYD Mexico plant stalled amid China fear of tech leak” — https://mexiconewsdaily.com/business/ft-byd-mexico-plant-stalled-china-fear-tech-leak/
Gibson Dunn, “FinCEN Issues Orders Declaring Three Mexican Financial Institutions of Primary Money Laundering Concern” — https://www.gibsondunn.com/fincen-issues-orders-declaring-three-mexican-financial-institutions-of-primary-money-laundering-concern-related-to-fentanyl-and-opioid-trafficking/

Canada

Innovation, Science and Economic Development Canada, “Guidelines on the National Security Review of Investments” — https://ised-isde.canada.ca/site/investment-canada-act/en/investment-canada-act/guidelines/guidelines-national-security-review-investments

ISED, “Annual Report 2024–2025 — Investment Canada Act” — https://ised-isde.canada.ca/site/investment-canada-act/en/home/annual-report-2024-2025

ISED, “Policy Regarding Foreign Investments from State-Owned Enterprises in Critical Minerals under the Investment Canada Act” — https://ised-isde.canada.ca/site/investment-canada-act/en/policy-regarding-foreign-investments-state-owned-enterprises-critical-minerals-under-investment

Norton Rose Fulbright, “2026 Thresholds for Review — Investment Canada Act” — https://www.nortonrosefulbright.com/en/knowledge/publications/34f06c7c/2026-thresholds-for-review-investment-canada-act-thresholds-increase

Stikeman Elliott, “Passage of Bill C-34: An Overhaul of Canada’s FDI Regime” — https://stikeman.com/en-ca/kh/competitor/passage-of-bill-c34-an-overhaul-of-canadas-fdi-regime

McCarthy Tétrault, “Government of Canada Orders Divestitures in the Critical Minerals Sector” — https://www.mccarthy.ca/en/insights/publications/government-canada-orders-divestitures-critical-minerals-sector

United States

U.S. Department of the Treasury / CFIUS, “2025 Annual Report to Congress” — https://www.cfius.gov/files/2025-cfius-annual-report.pdf
31 C.F.R. Parts 800, 801, 802 (CFIUS implementing regulations) — https://www.ecfr.gov/current/title-31/subtitle-B/chapter-VIII/part-800
Akin Gump, “President Trump Issues America First Investment Policy” — https://www.akingump.com/en/insights/alerts/president-trump-issues-america-first-investment-policy-refocusing-cfius-and-outbound-investment-approach
Latham & Watkins, “6 Key Takeaways From the 2025 CFIUS Annual Report” — https://www.lw.com/en/insights/6-key-takeaways-from-the-2025-cfius-annual-report
O’Melveny, “CFIUS Expands to Include Secretary of Agriculture” — https://www.omm.com/insights/alerts-publications/cfius-expands-to-include-secretary-of-agriculture/

European Union

Regulation (EU) 2019/452 — https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R0452
European Parliament, Legislative Train — “Revision of the FDI Screening Regulation” — https://www.europarl.europa.eu/legislative-train/carriage/revision-of-the-fdi-screening-regulation/report
Cleary Gottlieb, “The New EU FDI Screening Regulation Reaches the Finish Line” — https://www.clearygottlieb.com/news-and-insights/publication-listing/the-new-eu-fdi-screening-regulation-reaches-the-finish-line
White & Case, “Foreign Direct Investment Reviews 2026: Germany / France / Italy / European Union” — https://www.whitecase.com/insight-our-thinking/foreign-direct-investment-reviews-2026-european-union
Morgan Lewis, “Dutch and German Regulators Scrutinize Nexperia Transactions Amid US Export Pressures” — https://www.morganlewis.com/pubs/2025/11/dutch-and-german-regulators-scrutinize-nexperia-transactions-amid-us-export-pressures
Note on sourcing: content is drawn from law-firm client alerts and press reporting published between August 28 and September 3, 2026, and from primary-source Canadian, U.S., and EU statutory and regulatory materials. The Mexican bill’s own statutory text was not directly reviewed; the mechanics described in Part II reflect the consistent summary across the law-firm alerts cited above. Two points flagged in this briefing — the bill’s treatment of fideicomiso-held real estate and any appeal or judicial-review mechanism — could not be confirmed from public reporting as of this writing and should be verified against the Senate’s Gaceta Parlamentaria text once formal committee review begins. This briefing is provided for general informational purposes and does not constitute legal advice.

This article is for general informational purposes and does not constitute legal, tax, or financial advice. Legislative proposals and regulatory thresholds change; confirm current details with qualified counsel before relying on them.