Although Citi is the country's largest bank, the investment also should not trigger a national security review by the Treasury Department-led Committee on Foreign Investments in the U.S. A proposed purchase of port servicing operations in the U.S. by Dubai, another United Arab Emirates state, provoked Congress in 2007 to require that CFIUS examine acquisitions of "critical infrastructure" for national security implications. But the definition of infrastructure was directed at physical assets such as power and telecommunications grids and transportation hubs, said Clif Burns, a partner in the export controls practice group at Powell Goldstein LLP. "I'm not sure you could classify Citi as critical infrastructure."