While this is the CFIUS’ largest penalty to date, the committee likely did so to emphasize its aggressive stance on enforcing compliance going forward. In this case, the CFIUS has jurisdiction over T-Mobile because the carrier is primarily owned by Deutsche Telekom, a German entity. Since the committee was set up to oversee the national security implications of foreign business investments in the US, the CFIUS is within its rights to take action against companies for breaching the terms of their agreements, as it has with T-Mobile.
That said, it is unusual for the CFIUS to issue a penalty of this size. However, it’s worth noting that the committee has been doubling down on its attempts to prevent future violations. Given this, in the last 18 months alone, the CFIUS issued six penalties, ranging from $100,000 to $60 million.