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Nancy A. Fischer, Partner

Nancy A. Fischer

Partner
Washington, DC

Partner, Washington, DC

T: +1.202.663.8965
T: +1.202.663.8965

Areas of Focus

Fischer demonstrates ‘tremendous command of the regulations’ and has a ‘good sense of how businesses work.’
—Chambers USA

Nancy Fischer, Pillsbury's Global Head of Regulatory, is consistently recognized by Chambers and other publications as a leading authority on international trade law.

Nancy advises a global clientele on international trade matters and dispute resolution and the impact of U.S. regulations on worldwide trade and investments. She provides guidance on export controls, economic sanctions, CFIUS reviews, FCPA and other anti-bribery laws, trade remedies, customs laws, and WTO and NAFTA disputes. Nancy has represented large industry coalitions in disputes, including a group of nuclear utilities in the first antidumping matter before the U.S. Supreme Court.

Representative Experience

  • Navigated the Committee on Foreign Investment in the U.S. (CFIUS) review process for a Chinese government-owned client acquiring a global semiconductor equipment provider, successfully obtaining CFIUS clearance for the transaction.
  • Conducted extensive internal investigation on Foreign Corrupt Practices Act and Brazilian anti-corruption law compliance for a Japanese company investing in the Brazilian shipbuilding industry.
  • Conducted extensive internal investigation for a private security contractor regarding alleged criminal and civil violations of International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) and prepared comprehensive voluntary disclosures.

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  • Anti-Money Laundering
    • Advised cruise line with gambling operations on various aspects of U.S. anti-money laundering rules including casino AML programs, currency transfer, money services business, customer due diligence and other matters.
    • Revised Know-Your-Customer (KYC) sanctions guidelines for leading global provider of business, legal and financial services.
    • Assisted multiple clients on KYC, Customer Identification Program (CIP) and Enhanced Due Diligence (EDD) reviews and programs.
  • Customs Compliance & Enforcement
    • Advised U.S. mining equipment manufacturer on TIB compliance, successfully obtaining mitigation of nearly $100K in penalties.
    • Advised U.S. manufacturer on Federal Transit Administration Buy America requirements associated with components, subcomponents and manufacturing processes.
    • Advised large manufacturer on Harmonized Tariff Schedule (HTS) classification and prior disclosure issues in connection with imports of steel and glass construction materials.
    • Successfully advised U.S. and foreign companies in obtaining exclusions from tariffs on products imported from China under Section 301 of the Trade Act of 1974, representing millions of dollars in tariff savings.
    • Conducted internal reviews and prepared prior disclosures to CBP concerning compliance by an energy company with an antidumping duty order.
    • Advised a manufacturer on customs law origin marking requirements and Trade Agreements Act domestic content rules.
    • Assisted a global security solutions company in reviewing the country of origin of its products related to Buy America, Buy American and Trade Agreement Act Compliance.
  • Economic Sanctions & Embargoes
    • Advised global investment firm on U.S. sanctions risks associated with potential transaction to acquire a portfolio of aircraft.
    • Reviewed and analyzed sanctions issues in connection with potential acquisition of U.S.-based medical optics company by a publicly traded Japanese corporation.
    • Conducted a comprehensive review of life sciences company’s operations in sanctioned countries and assisted in the preparation of submission of a voluntary self-disclosure to OFAC.
    • Advised coalition of U.S. utilities in connection with potential sanctions impacting Russian fuel supply into the United States and engaged with the State and Treasury Departments regarding the same.
    • Counseled Chinese nuclear entity on proposed sanctions implications of acquisitions of uranium mine with partial ownership involving Iran.
    • Assisted U.S.-based fuel provider with OFAC application to release blocked funds and advised on licensing requirements involving Cuba.
    • Assisted financial institutions, real estate companies and other businesses on the negotiation of contract language addressing compliance with executive orders and sanctions regulations.
    • Advised borrowers and lenders in the tailoring of sanctions language to finance arrangements in light of planned business and compliance concerns.
    • Conducted internal investigation on printer manufacturer and its subsidiaries concerning Iran and Syria transactions, and prepared disclosures to OFAC and the Bureau of Industry and Security (BIS).
    • Assisted Chinese manufacturer of security products with sanctions-related analysis in connection with imports of North Korean labor.
    • Advised European manufacturers on the impact of the Joint Comprehensive Plan of Action (JCPOA) on U.S. and EU sanctions on Iran.
    • Evaluated whether certain activities may be in violation of U.S. secondary sanctions and risks related to SDN designation.
    • Advised U.S. and foreign companies on the complex interplay between U.S. sanctions and foreign antidote measures that target the extraterritorial application of U.S. laws and regulations, developing compliance strategies, and representing companies in multijurisdictional inquiries and enforcement proceedings.
    • Assisted U.S.-based global manufacturer on U.S. sanctions concerning transactions by subsidiary entities.
    • Advised foreign companies doing business in Cuba on potential risks due to the recently implemented Title III of the Helms-Burton Act.
    • Advised companies on the complexities of payments related to authorized JCPOA transactions.
    • Advised electronics company on OFAC compliance regarding sales of telecommunications devices to Cuba.
    • Drafted compliance manual and advised aircraft leasing and financing company on compliance with applicable sanctions laws, including sectoral sanctions applicable to long-term financing transactions.
    • Obtained licenses to unblock funds, permit shipments and (when required) authorize travel to countries subject to sanctions.
    • Assisted aerospace, airline and travel companies with understanding the JCPOA changes and navigating the OFAC licensing process for transactions with Iran.
    • Advised European air carriers with compliance and licensing issues in connection with proposed travel services to Iran and Cuba.
    • Advised international media company in connection with potential field work in embargoed destinations, seeking regulatory guidance and obtaining licensing.
    • Assisted major international aerospace manufacturers with licenses to ship aircraft and components to sensitive countries and implementing compliance programs.
    • Advised major manufacturing companies with compliance and licensing issues in connection with proposed exports of products to Cuba.
    • Advised global satellite service providers on OFAC licensing and compliance.
    • Advised cruise line on U.S. sanctions rules in relation to passengers, employees and operations. Obtained licenses related to Crimea sanctions. Advised on Cuba sanctions reform.
  • Export & Technology Transfer Controls
    • Advised cybersecurity and defense companies on the intersection between Controlled Unclassified Information, export controls and reporting requirements in connection with cyber incidents, deemed exports and third-party compliance requirements.
    • Advises global aerospace manufacturer on complex FMS TPT transaction and PM/RSAT approval involving multiple countries.
    • Provided ITAR and EAR subject matter expertise support in multiple locations to internal audit and assurance review exercises focused on export control and technology transfer controls in connection with ITAR consent agreement compliance for a global defense company.
    • Advised software developer in connection with export compliance related to software for telecommunications ground systems in connection with satellites and high-altitude platforms.
    • Advises major global nuclear and defense companies on U.S. export control compliance plan and DCSA and DOE FOCI mitigation for U.S. subsidiaries.
    • Represents Chinese semiconductor company added to the BIS Entity List on U.S. export compliance matters, including petitioning for removal from the Entity List.
    • Successfully obtains BIS export licenses for U.S. and non-U.S. semiconductor companies seeking to do business with parties on the Entity List, including Huawei.
    • Advised major UAS manufacturer by conducting a full audit of its ITAR compliance program and in advance of Directorate of Defense Trade Controls (DDTC) Company Visit Program visit, reviewing voluntary self-disclosure issues, classifying aircraft and related articles, and counseling on end-use requirements and license conditions.
    • Counseled aerospace software client regarding both U.S. government and self-classifications of aircraft and spacecraft-related software products, involving a Commodity Jurisdiction (CJ) reconsideration in light of export control reform, as well as engagement with government officials during dispute resolution procedures when CJ reviewing agencies disagreed.
    • Advised defense and commercial companies on cybersecurity attacks and guided them on voluntary disclosures resulting from potential export control violations.
    • Structured and prepared Technical Assistance, Manufacturing License and Distribution Agreements, as well as export and temporary import licenses submitted to DDTC for U.S. and foreign defense manufacturers, aerospace and software companies.
    • Designed and implemented export control internal compliance programs for domestic and multinational clients in the aviation, technology, satellite services and other industries.
    • Provided long-term onsite export control support to major defense company for implementation of ITAR consent agreement requirements including ITAR (brokering, technical data, classification issues), EAR and export control reform impact on compliance.
    • Assisted global defense manufacturers in evaluating the application of the ITAR to technology exported under the U.S. Foreign Military Sales (FMS) program.
    • Provided ITAR and EAR subject matter expertise support in multiple locations to internal audit and assurance reviews exercises focused on export control and technology transfer controls in connection with ITAR consent agreement compliance for a global defense company. Assisted clients in assessing export control requirements applicable to intelligence and surveillance products and technologies.
    • Advised global defense and intelligence technology services provider on Defense Security Cooperation Agency (DSCA) and ITAR compliance in connection with acquisition of U.S. software engineering firm.
    • Advised brokers of U.S. defense articles on revisions to licensing and registration requirements relating to activity in the Middle East.
    • Counseled Chinese manufacturer of telecommunications chipsets on various export control matters, including the direct product rule.
    • Advised Asian chip manufacturer with product having U.S. content on U.S. reexport rules, as well as encryption and Wassenaar export rules for Asian markets—Malaysia, Singapore, Korea.
    • Advised on and drafted export control provisions in master services agreements for outsourcing applications development and maintenance functions to offshore entities.
    • Advised electronics and semiconductor companies on compliance with encryption regulations under the EAR and related filings including registration, classification and reporting.
    • Advised a major aerospace manufacturer on classification and licensing issues related to the incorporation of ITAR controlled content in civil aircraft.
    • Advised a non-U.S. company on Commerce Department license exceptions relating to aircraft, the overlap of U.S. sanctions and export control policies, and obtaining licenses authorizing exports to a jurisdiction subject to U.S. sanctions.
    • Advised satellite company on compliance with ITAR and EAR rules including transition to EAR due to Export Control Reform.
    • Conducted extensive internal investigation related to alleged ITAR and EAR criminal and civil violations for a private security contractor and preparing comprehensive voluntary disclosures to DDTC, BIS and Census regarding exports of controlled items and provision of potential defense services.
    • Provided training sessions and internal assessments for global defense manufacturer on control of technology, technical data and derived data in the wake of U.S. export control reform.
    • Worked with a major electronics manufacturer to navigate the overlap of U.S. export controls and evolving sanctions policies for Iran, which permit certain sales of consumer electronics and services to enable internet access and communication.
    • Conducted internal investigation and designed a strategy of complementary licensing, Commodity Classification Automated Tracking System (CCATS) and voluntary disclosure filings to address the export of encryption software and potential prior violations.
  • Foreign Corrupt Practices Act (FCPA)
    • Advised major defense contractor on FCPA compliance in connection with potential sales to Middle East governments through required local country partners.
    • Conducted FCPA internal investigation for U.S. defense manufacturer in connection with sales and third-party agent activities in Mexico.
    • Advised international media company on FCPA best practices when hiring local agents in high-risk jurisdictions.
    • Advised Norwegian company on drafting and implementing a global anti-corruption compliance program including the FCPA, UK Bribery Act and Norwegian anti-corruption laws.
    • Prepared FCPA and China anti-corruption compliance policies and drafted anti-corruption clauses for distribution and local agent agreements for a U.S. manufacturing company expanding its business in China.
    • Conducted FCPA, UK Bribery Act and Chinese anti-corruption law training for many clients in the telecommunications, manufacturing, technology and life sciences sectors.
    • Assisted a U.S.-based airline with conducting a comprehensive FCPA review of its policies, practices and procedures and provided FCPA training.
  • Regulation of Foreign Investment & National Security
    • Successfully represented U.S. satellite communications provider in connection with an acquisition by an Australian global communications company. This matter involved comprehensive representation before multiple U.S. government agencies, including CFIUS, DCSA, DDTC and the FCC.
    • Acts as CFIUS counsel for multiple venture capital funds specializing in semiconductor investments.
    • Successfully responded to inquiries from CFIUS and the U.S. State Department related to an investment by a China-based fund in an ITAR-registered entity.
    • Successfully obtained CFIUS approval for a U.S.-based aerospace company regarding investment by Japanese entity. Assisted the seller in conducting a review of its export control classifications and procedures in order to facilitate the CFIUS review process and enhance the company’s export compliance.
    • Represents U.S. semiconductor company in approximately $10 billion acquisition by company subject to multiple National Security Agreements with CFIUS.
    • Represents various cloud computing and cloud networking companies on CFIUS in connection with company financings, including submission of related export control filings to facilitate CFIUS process. Also represented companies in this sector in responding to CFIUS non-notified inquiries.
    • Provides CFIUS counsel to China-based investment fund in connection with U.S. biotechnology investments, as well as advises on related export control compliance pertaining to U.S. operations.
    • Acts as CFIUS counsel in connection with photonics company $1.2 billion valuation merger with a Special Purpose Acquisition Company (SPAC).
    • Provides CFIUS counsel to venture capital firm in connection with a number of U.S. real estate investments.
    • Represents numerous U.S. artificial intelligence companies respond to CFIUS non-notified inquiries concerning minority investments by foreign parties.
    • Prepared CFIUS assessment for German entity with significant Chinese shareholders in connection with proposed acquisition of U.S.-based automotive supplier.
    • Counseled investment fund with global investor base on CFIUS implications of multiple investments across a variety of funds. Provided guidance on fund structure and requirements in light of the recently enacted CFIUS pilot program.
    • Assisted Chinese investor group in connection with potential acquisition of U.S. semiconductor company, including in-depth discussions and negotiations with CFIUS regarding potential mitigation options.
    • Represented Japanese investor through both the declaration and notice process in connection with a minority investment in a U.S. semiconductor company.
    • Counseled dozens of U.S. and non-U.S.-based emerging technology companies on implications of new CFIUS pilot program.
    • Successfully obtained CFIUS approval for a U.S.-based seller of technical surveillance solutions by a UK-based buyer. Assisted the seller in conducting a review of its U.S. government contracts and advised on potential Foreign Ownership, Control or Influence (FOCI) concerns.
    • Successfully obtained CFIUS approval on behalf of a U.S. IT services provider in its acquisition by Australian company, obtaining CFIUS approval and proposing a Special Security Agreement (SSA) with DSCA to mitigate FOCI.
    • Represented Italian company on CFIUS matters in connection with its acquisition of a U.S. testing company, including detailed analysis of potential application of the CFIUS pilot program.
    • Successfully navigated the CFIUS review process for a Chinese government-owned client in acquiring a global semiconductor equipment provider. Advised client on structural and other corporate transactional matters to minimize potential national security concerns.
    • Provided regulatory counseling to a group of Chinese investors in a potential acquisition of a semiconductor company. Advised client on transaction structure to address potential CFIUS issues and successfully obtained CFIUS clearance.
    • Provided U.S.-based semiconductor company with CFIUS risk assessment of potential foreign investors. Assisted company with CFIUS filing in connection with potential acquisition by Japanese company.
    • Successfully obtained CFIUS approval for a U.S.-based manufacturer/distributor of chemicals and diagnostics products regarding an acquisition by a China state-owned enterprise. Assisted seller in comprehensive review of its export control compliance matters and its sales to various U.S. government agencies to facilitate CFIUS review process.
    • Successfully obtained CFIUS approval for a U.S.-based cloud contact center software firm. Assisted the seller in conducting a review of its export control classifications and procedures in order to facilitate the CFIUS review process and enhance the company’s export compliance.
    • Successfully advised a European government-owned aerospace corporation on foreign ownership restrictions, involving extensive negotiations with DSCA, CFIUS and the State Department. Assisted with the Technology Control Plan and electronic communication plan and the SSA.
    • Assisted U.S. security screening company obtain CFIUS clearance in connection with potential foreign acquisition. Advised company on compliance with related notifications to other U.S. agencies, including DSCA.
  • Trade Remedy Proceedings
    • Successfully opposed tariffs on behalf of European crane manufacturer in Department of Commerce Section 232 investigation on mobile cranes.
    • Advised U.S. appliances manufacturer on Section 301 exclusion requests and public policy engagement.
    • Successfully obtained rare Department of Commerce approval for Japanese utility for uranium “swap” and reexport transaction under the Russian Suspension Agreement.
    • Successfully opposed imposition of tariffs or quotas on U.S. uranium imports on behalf of a nuclear industry coalition, known as the Ad Hoc Utilities Group (AHUG). We represent the AHUG coalition in Section 232 investigation on imports of uranium products, including engagement in public policy at high levels with multiple government agencies and the White House, advocacy before the Departments of Commerce, Defense, State and Energy, including in the Section 232 comments process, and analysis of potential remedies.
    • Represented U.S. fabricator on Section 232 investigation on uranium imports, including responses to industry surveys and advocacy before the DOC.
    • Represented Finnish producer and supplier of technologies, automation and services in U.S. Trade Representative proceedings concerning potential tariff increases on Chinese products in connection with Section 301 investigation on China’s intellectual property practices.
    • Advised large real estate investment trust regarding scope of various antidumping and countervailing duty orders to determine impact on relevant products.
    • Organized and represented nuclear industry coalition, AHUG, with unique standing in novel trade remedy dispute involving whether sales of services could be subject to the antidumping laws before DOC, ITC, Court of International Trade (CIT), Court of Appeals for the Federal Circuit (CAFC) and the first antidumping case at the U.S. Supreme Court.
    • Represented U.S. fabricator in DOC administrative reviews and changed circumstances review related to an antidumping duty order’s certification and reexport requirements involving impact of Japanese tsunami on reexport requirements.
    • Organized and represented AHUG in trade remedy dispute involving multiple sunset reviews and suspension agreement compliance in the Uranium from Russia case before the DOC, ITC and CIT.
    • Represented multiple Brazilian steel companies in antidumping and countervailing duty cases involving Flat-Rolled Carbon Steel Products from Brazil. Cases involved novel issues of the treatment of pre-privatization subsidies to post-privatized entities and involved appeals to the CIT and CAFC.
    • Represented Dutch subsidiary of Japanese parent company in antidumping case on Color Negative Photographic Paper and Chemical Components. Advised client on Section 301 investigation related to alleged trade barriers in Japan.

Professional Highlights

  • Recognized by Chambers Global and Chambers USA in International Trade, including Export Controls & Economic Sanctions, CFIUS, and Trade Remedies & Trade Policy.
  • Recognized by The Legal 500 U.S. for her work in International Trade (2015 – 2021). The Legal 500 U.S. named Nancy a Leading Lawyer in their 2020 and 2021 guides, with testimonial in the recent guide noting, “[Nancy Fischer] possesses unrivaled understanding of issues and regulatory process.”
  • Selected as a finalist for the Compliance Lawyer of the Year Award during the 2020 Women in Compliance Awards.

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  • Honors & Awards
    • Recognized by Best Lawyers (published by BL Rankings LLC), International Trade and Finance Law (2021 – 2023).
    • Recipient of JD Supra’s 2018 – 2019 Readers' Choice Award.
    • Profiled as a key member of Pillsbury’s Latin Lawyer 250-ranked practice in the region
  • Associations
    • Society for International Affairs
    • Trade Policy Forum
    • American Bar Association
    • Society for Satellite Professionals International
    • Swedish American Chamber of Commerce DC (board member, president and chair-elect)
    • University of Georgia Terry College of Business Alumni Board Member
  • Speaking Engagements (2018 – Present)
    • C5's 4th European Forum on FDI Reviews and CFIUS, “General Counsel Panel: What Keeps You Up at Night?”, June 7, 2023
    • Global Economic Sanctions, “Practical Guidance to Staying Compliant with Multiple Regimes” November 15 – 16, 2022
    • NEXTChina Conference, November 9 & 10, 2022. Moderator for “Rebuilding Trade Routes”
    • Defence Exports Conference, SAE Media Group: Global and Integrated use of Export Control and Sanctions: Enhanced use of Economic Weapons on Russia and Lessons Learned, London United Kingdom September 2022
    • ACI’s 8th National Conference on CFIUS, Recent, Significant CFIUS Transactions and What They Reveal about Future Deals: Lesser-Known Takeaways from Magnachip, Tencent, TikTok, ByteDance and More, Webinar/Live Program, April 26, 2022
    • Swedish American Chamber of Commerce, Global Sanctions and Export Control Response to Russian Invasion of Ukraine, March 10, 2022
    • Practising Law Institute’s Coping with U.S. Export Controls and Sanctions 2021, Information Communications and Technology Supply Chain Restrictions, Webinar/Live Program, December 9, 2021
    • ACI’s 15th Flagship Conference on U.S. Economic Sanctions, Innovations in Sanctions Screening, Webinar/Live Program, December 7 – 8, 2021
    • Swedish American Chamber of Commerce DC, U.S. Infrastructure Opportunities for Non-U.S. Companies and Buy America Challenges Webinar, December 2, 2021
    • ACI Sanctions Panel, the China Conundrum webinar, November 10, 2021
    • Increasing Use of List-Based Sanctions, Content Enablers Webinar, Oct 28, 2021
    • Identifying the Effects of Trade and Technology Controls and Related Requirements on M&A Transactions, Pillsbury Webinar for Corporate Group, October 28, 2021
    • CFIUS Presentation, JERA, October 20, 2021
    • Cambridge Forum Defense Exports, Sanctions Challenges, Charlottesville, October 19, 2021
    • Patria/Kongsberg Export Control Training Webinar, October 2021
    • SACC USA Executive Forum, Trade Panel, September 30, 2021
    • The Deal’s Structuring M&A and Private Equity Deals: The CFIUS Challenge in Getting Deals Done, Webinar, September 23, 2021
    • The Entity List: What's Keeping You up at Night? MEU, MIEU and CCMC Regulations: New Enforcement Risks—and the Hidden Lessons for Updating Compliance and Licensing Practices, ACI U.S.-China Trade Controls webinar, September 20, 2021
    • SMI Defense Exports Conference, Supply Chain Challenges for Defense Contractors in a Post-COVID-19 World, London, September 15, 2021
    • Sanctions in the Era of Brexit & Biden: What the Past Six Months Tell Us about the Future, Webinar, June 30, 2021
    • C5’s 2nd European Forum on FDI Reviews and CFIUS, Virtual Forum, May 20, 2021
    • Federal Cyber Procurement: Navigating Risk and Winning Contracts, May 10, 2021
    • 7th National Conference on CFIUS, Webinar, April 20, 2021
    • Source Intelligence’s How to Identify and Prevent Forced Labor in Your Supply Chain, Webinar, April 8, 2021
    • AAMA CFIUS 2021 Roundtable, Webinar, April 1, 2021
    • C5’s Virtual European Forum on Economic Sanctions Risk and Compliance, Webinar, February 22, 2021
    • Practising Law Institute’s Investing, Trading and Doing Deals Conference, Webinar, February 18, 2021
    • American Conference Institute's U.S.-China Trade Controls Conference, Post-Election Briefing, Webinar, December 8, 2020
    • Pillsbury Presentation, 5G Rollout—Business, Technology and Legal Challenges, Webinar, November 11, 2020
    • NEI's 2020 International Uranium Fuel Seminar, Russian Suspension Agreement Roundtable, Webinar, October 21, 2020
    • ACI’s 13th Annual Flagship Conference on Economic Sanctions, Navigating Secondary Sanctions Risk with Respect to Clients, Counterparties and Other Third Parties, Webinar, July 29, 2020
    • ACI’s 6th National Conference on CFIUS, Addressing the Implications of CFIUS’s Expanded Jurisdiction over Critical Technology and the Interplay with Current Export Control Reform, Webinar, July 15, 2020
    • Swedish American Chamber of Commerce DC Presentation, New Stimulus, Trade and Political Developments, Webinar, May 12, 2020
    • Pillsbury Presentation with Stifel, Frost Capital and Atlantic Bridge, What Does the Future Hold for Technology Companies?, Webinar, April 28, 2020
    • Pillsbury CLE Presentation, Latest on CFIUS and Technology Export Controls, Austin, March 4, 2020
    • Pillsbury CLE Presentation, Latest on CFIUS and Technology Export Controls, Silicon Valley, March 3, 2020
    • Association of Suppliers to the Paper Industry Spring Meeting, Trade and Policy Actions Impacting the Paper Industry, Key Largo, Florida, February 27, 2020
    • PLI’s Investing, Trading and Doing Deals 2020 Program, Technology Controls (Innovation, Acceleration, Convergence and Control), New York, February 20, 2020
    • C5’s 8th London Forum on Global Economic Sanctions, London, November 19, 2019
    • Trends in M&A and CFIUS Reviews, Anderson Mori, Tokyo, October 16, 2019
    • 5th Asia Pacific Summit on Economic Sanctions Compliance and Enforcement, Focus on Russia Sanctions: Mastering the Challenges of Complying with Rapidly Changing Primary and Secondary Sanctions Panel, Singapore, October 15, 2019
    • 5th Asia Pacific Summit on Economic Sanctions Compliance and Enforcement, Intersection of Sanctions & AML: How to Coordinate Anti-Money Laundering and Sanctions Compliance Controls, Singapore, October 14, 2019
    • 14th Annual SMi Defence Exports Conference: Defense Supply Base and Emerging Technology Export Controls, Amsterdam, September 25 – 26, 2019
    • Asia America MultiTechnology Association & Pillsbury’s CFIUS, Export Controls and National Security Implications for Emerging Technologies Event, Palo Alto, September 18, 2019
    • ABA Aircraft Financing Subcommittee 2019 Fall Meeting, U.S. Regulations and Current Issues for International Trade, Washington, DC, September 12, 2019
    • Swedish American Chamber of Commerce Washington, DC, Women’s Leadership Forum, Current International Trade Hot Topics, Washington, DC, June 24, 2019
    • Chartwell Strategy Group’s U.S. and China Discussion, featuring Washington legal, policy, and political advisors, Washington, DC, June 19, 2019
    • Pillsbury’s CFIUS and Technology Transfers: What Emerging Technology Companies Need to Know, Webinar, May 1 & June 4, 2019
    • Swedish Embassy Defense Conference, CFIUS and Export Control Reform Act, Washington, DC, May 16, 2019
    • C5’s 13th Annual Forum on Global Economic Sanctions, Overview of Recent Restrictions and Practical Tips for Staying Compliant, Berlin, May 22, 2019
    • Pillsbury’s Annual East Coast Government Contracts Summit, CFIUS Developments for M&A of Government Contractors, Tysons, Va., May 14, 2019
    • ACI's 12th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance, Intersection of Sanctions and Export Controls and the New Export Control Reform Act of 2018, Washington, DC, May 2, 2019
    • World Nuclear Fuel Cycle Conference, Navigating U.S. Trade Laws and Supply Chain Security, Miami, April 9 – 11, 2019
    • Pillsbury’s Silicon Valley CFIUS Update with AAMA, China, CFIUS and International M&A in 2019: What Executives and Board Members Need to Know, Palo Alto, February 5, 2019
    • French American Chamber of Commerce panel discussion, Trump Administration Trade Actions, Washington, DC, January 22, 2019
    • PLI Program, Coping with U.S. Export Controls and Sanctions 2018—Export Control Reform and CFIUS, Washington, DC, December 13 – 14, 2018
    • Amcham Finland, Legal Update: How Renewed U.S. Sanctions Will Affect Finnish Companies, Helsinki, December 4, 2018
    • C5's 7th Conference on Economic Sanctions and Financial Crime, Drafting and Negotiating Sanctions and AML Clauses and Compliance Provisions in Agreements, London, November 14 – 15, 2018
    • ACC Aircraft Leasing Conference, Economic Sanctions Update, London, November 7, 2018
    • Ashurst Annual GC Conference, Managing Political and Economic Uncertainty, London, November 7, 2018
    • U.S. Withdrawal from the Iran Nuclear Deal: Implications for Indian Companies, Webinar, Pillsbury and Khaitan & Co, October 4, 2018.
    • 13th Annual SMi Defence Exports Conference: Intersection of U.S. Export Controls, Foreign Investment and National Security, Rome, September 19, 2018
    • CFIUS and Private Equity Seminar, June 19, 2018
    • C5 Trade Compliance Nordics, Global Trade Sanctions Compliance and Monitoring Workshop, Stockholm, June 11, 2018.
    • 45th Annual World Nuclear Fuel Market Conference: DOC Uranium Trade Cases, Monterey, Calif., June 5, 2018
    • U.S. Withdrawal from the Iran Nuclear Deal: Implications for Foreign Companies Doing Business with Iran, U.S. India Business Council, May 31, 2018 and Pillsbury and Khaitan & Co, October 4, 2018
    • AAMA and Pillsbury Seminar, China, CFIUS and International M&A, Silicon Valley, May 16, 2018
    • NEI Export Control Seminar, Impact of Proposed CFIUS Changes on Nuclear Trade and Investment, February 28, 2018
  • Publications (2018 – Present)
    • Russia Invades and the West Reacts: A Look at Russian Sanctions So Far, Authors: Christopher R. Wall, Stephan E. Becker, Nancy A. Fischer, Steven Farmer, Benjamin J. Cote, Aaron R. Hutman, Matthew R. Rabinowitz, Scott Morton, Roya Motazedi, Zachary C. Rozen, Toochi L. Ngwangwa, Mark Booth, Samantha Franks, 02/25/2022
    • New Infrastructure Law Brings Significant Investments in Drinking Water and Wastewater Infrastructure, Authors: Nancy A. Fischer, Benjamin J. Cote, Moushami P. Joshi, Aimee P. Ghosh, 02/09/2022
    • Opportunities Abound after House Passes $1.2 Trillion Infrastructure Investment and Jobs Act, Authors: Nancy A. Fischer, Elizabeth Vella Moeller, Craig J. Saperstein, Benjamin J. Cote, Moushami P. Joshi, Aimee P. Ghosh, Johnna Purcell, Johnna Purcell, 11/08/2021
    • Senate Passes $1.2 Trillion Infrastructure Package, Tees up $3.5 Trillion Budget Reconciliation Bill, Authors: Nancy A. Fischer, Elizabeth Vella Moeller, Craig J. Saperstein, Aimee P. Ghosh, Rose Fowler Lapp, Meghan Claire Hammond, 08/12/2021
    • New GSA Regulations Governing Foreign Ownership Disclosure, Authors: Alex D. Tomaszczuk, David L. Miller, Nancy A. Fischer, 07/08/2021
    • Biden Administration Updates Framework for China-Related Investment Prohibitions and Expands the Scope of Restricted Chinese Companies, Authors: Nancy A. Fischer, Aaron R. Hutman, Matthew R. Rabinowitz, Toochi L. Ngwangwa, 06/15/2021
    • China Passes Sweeping Anti-Foreign Sanctions Law, Authors: Nancy A. Fischer, Jenny (Jia) Sheng, Chunbin Xu, Matthew R. Rabinowitz, Jack Ko, Ph.D., Fang Wang, 06/15/2021
    • China’s MOFCOM Issues Internal Export Control Program Guidelines, Authors: Nancy A. Fischer, Jenny (Jia) Sheng, Chunbin Xu, Matthew R. Rabinowitz, Jack Ko, Ph.D., Fang Wang, Toochi L. Ngwangwa, 05/12/2021
    • Federal Support for Defense Uses of Advanced Nuclear, Authors: Nancy A. Fischer, Elina Teplinsky, Benjamin J. Cote, Aaron R. Hutman, Jeffrey S. Merrifield, Sidney L. Fowler, 02/03/2021
    • Congress Requires Foreign Ownership Disclosures for Federal Government Tenancies of “High-Security Leased Spaces,” Authors: Alex D. Tomaszczuk, Nancy A. Fischer, Matthew R. Rabinowitz, Stephanie T. Rosenberg, 01/08/2021
    • Trump vs. Biden: An International Trade Briefing, Authors: Stephan E. Becker, Nancy A. Fischer, Elizabeth Vella Moeller, Matthew Oresman, Stephanie T. Rosenberg, 10/29/2020
    • Trump vs. Biden: A Foreign Policy Brief, Authors: Nancy A. Fischer, Elizabeth Vella Moeller, Matthew Oresman, 10/28/2020
    • Indian Government Announces New Opportunities for Defense Contractors and Investors, Authors: Nancy A. Fischer, Moushami P. Joshi, Dinesh Dharmadasa, Marques O. Peterson, 10/22/2020
    • U.S. Steps Up Pressure on Iran with Sanctions on Additional Financial Institutions and Continuation of Arms Embargo, Authors: Christopher R. Wall, Nancy A. Fischer, Stephan E. Becker, Aaron R. Hutman, Matthew R. Rabinowitz, Sahar J. Hafeez, Roya Motazedi, Toochi L. Ngwangwa, 10/12/2020
    • U.S. Commerce Department Implements Multilateral Controls on Six Emerging Technologies, Authors: Christopher R. Wall, Nancy A. Fischer, Benjamin J. Cote, Zachary C. Rozen, Toochi L. Ngwangwa, 10/7/2020
    • U.S. Commerce Department Announces Prohibited Transactions Related to WeChat and TikTok but Implementation Is Delayed, Authors: Nancy A. Fischer, Christopher R. Wall, Stephan E. Becker, Aaron R. Hutman, Matthew R. Rabinowitz, Toochi L. Ngwangwa, 9/20/2020
    • CFIUS Issues Final Rule Basing Mandatory Declaration Requirement on U.S. Export Control Criteria, Authors: Nancy A. Fischer, Christopher R. Wall, Matthew R. Rabinowitz, Zachary C. Rozen, 9/16/2020
    • House and Senate Pass NDAA Bills that Include Expanded U.S. Sanctions on Nord Stream 2 Pipeline Construction and State Department Expands CAATSA Section 232 Guidance on Export Energy Pipelines, Authors: Christopher R. Wall, Nancy A. Fischer, Stephan E. Becker, Matthew R. Rabinowitz, Roya Motazedi, Stephanie T. Rosenberg, 8/12/2020
    • Executive Orders Target TikTok and WeChat Application Makers, Authors: Nancy A. Fischer, Christopher R. Wall, Aaron R. Hutman, Matthew R. Rabinowitz, Zachary C. Rozen, 8/10/2020
    • U.S. Government Efforts to Eliminate Supply Chain Threats from China to Telecommunications Networks, Authors: Stephan E. Becker, Nancy A. Fischer, Marques O. Peterson, Lee G. Petro, Matthew R. Rabinowitz, Zachary C. Rozen, 6/5/2020
    • U.S. Government Efforts to Eliminate Supply Chain Threats from China to Telecommunications Networks, Authors: Stephen E. Becker, Nancy A. Fischer, Marques O. Peterson, Lee G. Petro, Matthew R. Rabinowitz, Zachary C. Rozen, 6/5/2020
    • DoD Bans Use of Russian-Sourced Energy at U.S. Military Bases in Europe, Authors: Nancy A. Fischer, Dinesh Dharmadasa, Marques O. Peterson, Sahar J. Hafeez, 06/04/2020
    • Senate Bill Could Result in De-Listing of Certain Chinese Companies and Non-Chinese State-Owned Enterprises from U.S. Securities Exchanges, Authors: Nancy A. Fischer, Matthew Oresman, Matthew R. Rabinowitz, Jenny Y. Liu, Justin S. Platt, Zachary M. Kessler, Stephanie T. Rosenberg, 06/03/2020
    • BIS Adds 33 Chinese Entities to Entity List, Authors: Nancy A. Fischer, Stephen E. Becker, Aaron R. Hutman, Matthew R. Rabinowitz, Roya Motazedi, 5/23/2020
    • CFIUS Proposes Mandatory Declaration Requirement Based on U.S. Export Control Criteria, Authors: Christopher R. Wall, Nancy A. Fischer, Matthew R. Rabinowitz, Roya Motazedi, Zachary C. Rozen, 5/22/2020
    • BIS Amends Direct Product Rule to Target Huawei but Extends Huawei Temporary General License, Authors: Christopher R. Wall, Nancy A. Fischer, Stephen E. Becker, Matthew R. Rabinowitz, Zachary C. Rozen, 5/15/2020
    • CFIUS and Critical Technologies: Implications for the Biotechnology and Life Sciences Sector, Authors: Nancy A. Fischer, Matthew R. Rabinowitz, Zachary C. Rozen, Steven Meltzer, Joel Simon, 5/5/2020
    • New Filing Fees for CFIUS Notices Enter Into Effect, Authors: Nancy A. Fischer, Christopher R. Wall, Matthew R. Rabinowitz, Zachary C. Rozen, Roya Motazedi, 5/5/2020
    • New Export Control Rules Confront Integration of Civilian and Military Technology Development in China, Russia and Venezuela, Authors: Christopher R. Wall, Stephan E. Becker, Nancy A. Fischer, Aaron R. Hutman, Benjamin J. Cote, Matthew R. Rabinowitz, Zachary C. Rozen, Mario A. Torrico, 4/29/2020
    • Treasury and CBP Temporary Rule on 90-Day Deferment for Payment of Certain Duties, Authors: Stephan E. Becker, Nancy A. Fischer, Sahar J. Hafeez, Mario A. Torrico, 4/27/2020
    • Examining CFIUS Implications for the Real Estate Market in the Post-COVID-19 World, Authors: Nancy A. Fischer, Matthew R. Rabinowitz, Zachary C. Rozen, 4/22/2020
    • Executive Order Establishes New Committee to Review Foreign Investment in Communications Companies, Authors: Glenn S. Richards, Lee G. Petro, Jessica T. Nyman, Christopher R. Wall, Nancy A. Fischer, Matthew R. Rabinowitz, Zachary C. Rozen, 4/10/2020
    • Temporary FEMA Rule: Export Approvals Required for Certain Personal Protective Equipment, Authors: Nancy A. Fischer, Stephan E. Becker, Aaron R. Hutman, Matthew R. Rabinowitz, Sahar J. Hafeez, Mario A. Torrico, 4/10/2020
    • Mitigating CFIUS Risks for Foreign Lenders and Investors as Defaults and Uncertainty Mount in the COVID-19 World, Authors: Nancy A. Fischer, Christopher R. Wall, Matthew R. Rabinowitz, Joel Simon, Leo Crowley, Andrew Troop, Russell DaSilva, 4/3/2020
    • USTR Launches New Exclusion Request Procedure to Address COVID-19, Authors: Stephan E. Becker, Nancy A. Fischer, Sahar J. Hafeez, Mario A. Torrico, 3/24/2020
    • CFIUS Update: Chinese Company Ordered to Divest Acquisition of U.S. Hotel Software Company, Authors: Christopher R. Wall, Nancy A. Fischer, Matthew R. Rabinowitz, Roya Motazedi, 3/10/2020
    • CFIUS Unveils Proposed Rule to Impose Filing Fees, Christopher R. Wall, Nancy A. Fischer, Matthew R. Rabinowitz, Roya Motazedi, 3/9/2020
    • U.S. Expands Secondary Sanctions to Iran’s Industrial Sectors, Authors: Christopher R. Wall, Nancy A. Fischer, Aaron R. Hutman, Moushami P. Joshi, Matthew R. Rabinowitz, Zachary C. Rozen, Roya Motazedi, 01/17/2020
    • Compliance in 2020—Key Takeaways from the ITAR Cloud Rule, Authors: Christopher R. Wall, Stephan E. Becker, Nancy A. Fischer, Benjamin J. Cote, Mario A. Torrico, 1/16/2020
    • Key Takeaways from CFIUS Final Rules Implementing FIRRMA, Authors: Christopher R. Wall, Nancy A. Fischer, Matthew R. Rabinowitz, Roya Motazedi, Zachary C. Rozen, 1/15/2020
    • District Court Overturns OFAC Fine against Exxon, Authors: Christopher R. Wall, Nancy A. Fischer, Stephan E. Becker, Aaron R. Hutman, Matthew R. Rabinowitz, Zachary C. Rozen, 1/13/2020
    • Commerce Department Publishes Interim Final Rule Controlling Geospatial Imagery Software for Training IA, Authors: Christopher R. Wall, Nancy A. Fischer, Benjamin J. Cote, Matthew R. Rabinowitz and Mario A. Torrico, 1/10/2020
    • Commerce Department Issues New Proposed Rules on Telecommunications Supply Chain, Authors: Christopher R. Wall, Stephan E. Becker, Nancy A. Fischer, Glenn S. Richards, Aaron R. Hutman, Benjamin J. Cote, Matthew R. Rabinowitz, 11/27/2019
    • New Proposed CFIUS Regulations Implementing FIRRMA, Authors: Christopher R. Wall, Nancy A. Fischer, Aaron R. Hutman, Matthew R. Rabinowitz, Jorge Vera, Roya Motazedi, 9/23/2019
    • Trump Administration to Impose Tariffs on List 4 Products, Authors: Nancy A. Fischer, Stephen E. Becker, Sahar J. Hafeez, Stephanie Rosenberg, 8/5/2019
    • DHS's New Criminal Enforcement Initiative to Prosecute Corporations for Forced Labor, Authors: Nancy A. Fischer, Stephan E. Becker, William M. Sullivan Jr., Fabio Leonardi, Sahar J. Hafeez, 8/5/19
    • Update on U.S. Government Review of “Emerging and Foundational” Technologies, Authors: Nancy A. Fischer, Stephen E. Becker, Matthew R. Rabinowitz, Sahar J. Hafeez, 7/29/2019
    • Slavery in Supply Chains: CBP Petitions Raise New Forced Labor Compliance Risks, Authors: Nancy A. Fischer, Sahar J. Hafeez, Fabio Leonardi, Stephanie T. Rosenberg, 07/25/19
    • Huawei Remains on the BIS Entity List but Senior Officials Suggest Export Licenses May Be Considered, Authors: Christopher R. Wall, Nancy A. Fischer, Aaron R. Hutman, Matthew R. Rabinowitz, Stephanie Rosenberg, 7/16/2019
    • Cuba Travel Update: U.S. Regulators Amend Key Rules, Authors: Stephan E. Becker, Nancy A. Fischer, Aaron R. Hutman, Jorge Vera, 6/04/2019
    • The Trump Administration Initiates a Tariff Exclusion Process for Chinese Imports Provided in List 3, Authors: Nancy A. Fischer, Stephan E. Becker, Sahar J. Hafeez, Stephanie Rosenberg, 5/24/2019
    • Temporary General License Grants Huawei Limited Relief from Restrictions Imposed by Entity List Restrictions, Authors: Stephan E. Becker, Christopher R. Wall, Nancy A. Fischer, Aaron R. Hutman, Benjamin J. Cote, Sahar J. Hafeez, Stephanie Rosenberg, 5/23/2019
    • USTR Issues Proposed Tariff List on Nearly $300 Billion of Chinese Goods, Authors: Nancy A. Fischer, Stephan E. Becker, Sahar J. Hafeez, 5/15/2019
    • Further Escalation of Trade War: Trump Administration Raises Tariffs on Chinese Products, Authors: Stephan E. Becker, Nancy A. Fischer, Sahar J. Hafeez, Stephanie Rosenberg, 5/9/2019
    • U.S. and EU Propose Steep Tariffs in Connection with Long-Running Parallel Disputes over Disputed Subsidies to Airbus and Boeing, Authors: Stephan E. Becker, Nancy A. Fischer, Sahar J. Hafeez, Roya Motazedi, 4/30/2019
    • U.S. State Department Implements Title III of Helms-Burton Act Permitting Lawsuits Over Seized Properties in Cuba, Authors: Stephan E. Becker, Christopher R. Wall, Nancy A. Fischer, Sahar J. Hafeez, Roya Motazedi, 4/18/2019
    • U.S. Commerce Department Releases Proposed Rulemaking for Export Controls on Emerging Technologies, Authors: Christopher R. Wall, Nancy A. Fischer, Stephan E. Becker, Aaron R. Hutman and Matthew R. Rabinowitz, 11/20/2018
    • U.S. State Department Adds New Hotels to Cuba Restricted List, Authors Nancy A. Fischer, Stephan E. Becker and Matthew R. Rabinowitz, 11/19/2018
    • OFAC Announces Sanctions against Saudi Arabian Government Officials Pursuant to Global Magnitsky Act, Authors: Christopher R. Wall, Nancy A. Fischer, Stephan E. Becker, Aaron R. Hutman and Matthew R. Rabinowitz, 11/15/2018
    • Reinstatement of Iran Sanctions, Authors: Christopher R. Wall, Stephan E. Becker, Nancy A. Fischer, Aaron R. Hutman, Matthew R. Rabinowitz, Moushami P. Joshi and Jorge Vera, 11/5/2018
    • CFIUS Announces Pilot Program Requiring Mandatory Declarations for Certain Non-Controlling Investments in Specified Critical Technology Companies, Authors: Christopher R. Wall, Nancy A. Fischer, Stephan E. Becker and Matthew R. Rabinowitz, 10/11/2018
    • Fall 2018 CFIUS Briefing, Authors: Nancy A. Fischer, Julian Zou, Matthew R. Rabinowitz, Thomas M. Shoesmith, 9/24/18
    • State Department Imposes Chemical Weapons Sanctions on Russia, Authors: Christopher R. Wall, Nancy A. Fischer, Aaron R. Hutman, Benjamin J. Cote and Jorge Vera, 8/17/2018
    • U.S. Formalizes Snap-Back of Sanctions with New Executive Order, Authors: Christopher R. Wall, Stephan E. Becker, Nancy A. Fischer, Aaron R. Hutman and Matthew R. Rabinowitz, 8/8/2018
    • Congress Reaches Agreement on CFIUS Reform Legislation Broadening National Security Reviews and Addressing Emerging Technologies, Authors: Christopher R. Wall, Nancy A. Fischer and Matthew R. Rabinowitz, 7/30/2018
    • The Trump Administration Further Escalates Tariffs on Chinese Products, Authors: Nancy A. Fischer, Sahar J. Hafeez and Jorge Vera, 7/20/2018
    • CFIUS: Inadvertent “Foreign Person” Status, Authors: Nancy A. Fischer, Matthew R. Rabinowitz, Julian Zou, Thomas M. Shoesmith, 07/09/18
    • The Inadvertent “Foreign Person” Trap for American Cos., Law360, Authors: Nancy A. Fischer, Matthew R. Rabinowitz, Thomas M. Shoesmith, 06/27/18
    • Differing CFIUS Reform Bills Move Through U.S. House and Senate, Authors: Nancy A. Fischer and Matthew R. Rabinowitz, 6/26/2018
    • Tariff Wars Escalate: USTR Announces Tariff Increases on a Wide Range of Chinese Products and China Responds with Tariffs on U.S. Products, Including Agriculture, Whiskey and Autos, Authors: Stephan E. Becker, Nancy A. Fischer and Sahar J. Hafeez, 6/25/2018
    • Car Wars: Trump Administration Opens Section 232 Investigation into Imports of Autos and Auto Parts, Authors: Stephan E. Becker, Nancy A. Fischer, Benjamin J. Cote, Sahar J. Hafeez and Crystal Fomba, 5/30/2018
    • New Proposed Trade Legislation Contains Additional Trade and Investment Restrictions Involving China, Authors: Nancy A. Fischer, Stephan E. Becker, Matthew R. Rabinowitz and Sahar J. Hafeez, 5/18/2018
    • United States Announces Withdrawal from JCPOA, Authors: Christopher R. Wall, Stephan E. Becker, Nancy A. Fischer, Aaron R. Hutman and Matthew R. Rabinowitz, 5/8/2018
    • Trump Administration Considering Use of IEEPA to Restrict U.S. Technology Transfer to China, Authors: Nancy A. Fischer, Christopher R. Wall and Matthew R. Rabinowitz, 4/12/2018
    • Spring 2018 CFIUS Briefing, Authors: Matthew R. Rabinowitz, Nancy A. Fischer, Julian Zou, Thomas M. Shoesmith, 4/10/18
    • Trump Administration Takes Action on Trade with China, Authors: Stephan E. Becker, Nancy A. Fischer, Sahar J. Hafeez, 03/23/18
    • CFIUS and China: Separating Fact from Fiction, Authors: Nancy A. Fischer, Matthew R. Rabinowitz, Julian Zou, Thomas M. Shoesmith, 02/12/18

Education

  • J.D., Syracuse University College of Law, 1992
    magna cum laude, Law Review

    B.B.A., University of Georgia, 1989
    cum laude

Admissions

  • District of Columbia

    New York

Courts

  • U.S. Supreme Court

    U.S. Court of Appeals for the Federal Circuit

    U.S. Court of International Trade

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