Alert 04.29.26
President Issues Defense Production Act Determinations Targeting U.S. Energy Sector
New DPA Determinations Enable Federal Support for Energy Infrastructure, Fossil Fuels and Grid Supply Chains
Sahar Hafeez focuses her practice on international trade, national security and supply chains, and co-leads Pillsbury’s Minerals, Metals and Materials Supply Chain practice.
Sahar advises companies across multiple industries, including the minerals, semiconductor, nuclear energy and manufacturing industries, on international trade and national security matters, including supply chain vulnerability assessments, strategies for supply chain diversification, investments to secure supply chains, import restrictions and tariff mitigation, export controls, investment security, digital trade (including border data flows), and international trade and economic security policies. Previously, Sahar served at the U.S. Department of Commerce’s International Trade Administration and Bureau of Industry and Security and as Director of International Economics at the White House National Security Council, where she led and advised on semiconductor and mineral supply chains and digital trade.
Representative Experience
- Represented the Ad Hoc Utilities Group, a coalition of leading U.S. nuclear utilities, in trade remedy proceedings and negotiations related to the Suspension Agreement on Uranium from Russia, Section 232 investigations, nuclear fuel supply legislation and the 2026 Critical Materials Assessment.
- Advised clients across industries, including utilities, manufacturing, aerospace and semiconductors, on Section 232 investigations of critical minerals and copper, preparing regulatory submissions, engaging with government agencies, providing supply chain diversification strategies, and providing ongoing counsel regarding trade and tariff matters.
- Advised clients across industries, including manufacturing, energy, nuclear fuel, art and collectibles, on Section 232 and 301 tariffs, IEEPA measures, and related compliance, risk management and duty mitigation strategies under shifting U.S. trade policies.
View More
- Advised global industrial manufacturers on U.S. trade compliance, including Section 301 and 232 tariffs, IEEPA measures, classification and domestic content rules, and advocacy before federal agencies.
- Advised a U.S. nuclear fuel fabricator on compliance with the Russian Suspension Agreement, uranium import ban waivers, and related tariff, sanctions, export control and trade policy matters.
- Advised the Ad Hoc Utilities Group, a coalition of major U.S. nuclear utilities, on trade remedy proceedings, uranium import restrictions, and legislative and regulatory developments affecting nuclear fuel supply.
- Advised OEM in defense industry regarding assessing mineral supply chain risks, strategies for diversification of at-risk supply chains, and compliance with sourcing restrictions under the DFARS related to specialty metals.
- Advised U.S. producer of metal powders regarding compliance with DFARS sourcing restrictions related to specialty metals.
- Advised U.S. nuclear utilities in connection with various proceedings impacting nuclear fuel supply, including Section 232 national security investigation on uranium imports by domestic mining companies in parallel with antidumping proceedings, and related executive and congressional initiatives. Advocacy included preparing response comments and conducting high-level meetings at the White House and various agencies.
- Represented U.S. manufacturer in Section 232 investigation into copper imports.
- Successfully opposed tariffs on behalf of European crane manufacturer in Department of Commerce Section 232 investigation on mobile cranes.
- 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 manufacturer on HTS classification and prior disclosure issues in connection with imports of steel and glass construction materials.
- Advised software company on compliance with encryption regulations under the EAR.
- Advised global technology company on system-wide approach to services for sanctioned parties; assessing general licenses and Berman Amendment.
- Government experience (prior to joining Pillsbury)
- Led the June 2021 White House 100-Day Review of the Semiconductor Manufacturing and Advanced Packaging Supply Chain; co-led and drafted the September 2021 Request for Information on risks in the semiconductor supply chain to identify vulnerable nodes in the supply chain.
- Produced mineral-by-mineral supply chain assessments and U.S. government policy recommendations.
- Convened producer and consumer industry and investors to drive investment in minerals.
- Advised Department of Commerce and White House on a Section 232 investigation on rare earth magnets.
- Led for the Department of Commerce a U.S. Department of Commerce-Norwegian Ministry of Trade, Industry, and Fisheries report on non-market policies and practices impacting mineral markets.
- Led for the U.S. negotiations and international partners on mineral supply chains.
- Led the development of Executive Order 14086 regarding signals intelligence, which implemented U.S. commitments under the EU-U.S. Data Privacy Framework, and related negotiations with the EU.
- Managed the U.S.-EU Trade and Technology Council.
Professional Highlights
Government Service
- Senior Advisor to Assistant Secretary for Industry and Analysis, Department of Commerce
- Senior Advisor to Under Secretary for Industry and Security, Department of Commerce
- Director of International Economics, White House National Security Council
- Special Assistant General Counsel, Office of U.S. Trade Representative
View More
-
Pro Bono
-
Sahar has helped non-governmental organizations prepare petitions requesting the U.S. government to sanction individuals under the Global Magnitsky Human Rights Accountability Act, conducted analysis of damages awarded in federal cases involving human trafficking claims, and successfully spearheaded an American Bar Associations Report and Resolution on U.S. policy responses to the Rohingya refugee crisis.
-
- Received Pro Bono Achievement Award
- Received 2019 American Bar Association Outstanding Volunteer Award
- Awarded the CALI Excellence Award for Legal Research and Writing
- Recognized by Super Lawyers as Rising Star 2017, 2018, 2019
- Affiliations
- Council on Foreign Relations, Term Member (2021–Present)
- Foreign Policy for America, Board Member (2020–2021)
- Human Trafficking Legal Center, Advisory Board (2018–2021)
- University Club of Washington, DC, International Committee, Member (2018–2021)
- Atlantic Council Nuclear Energy and National Security Coalition, Member (2019–2020)
- ABA, International Trade Committee, Vice-Chair (2017–2020)
- Publications
- Case Note on the Federal Circuit Court of Appeals’ Analysis Regarding the Scope of Review of the Post-Grant Review by the Patent Trial and Appeal Board in the Case of Versata Development Group Inc. and SAP AG
- “Leveling the Playing Field for American Companies and Workers – Ensuring that Goods Made with Forced Labor Are Identified and Banned Pursuant to U.S. Law”
- “U.S.-Cuba Related Sanctions Update and Overview: Obama Administration Further Eases Cuba Sanctions Against the Backdrop of Strict Statutory Restrictions”
- “Elimination of a Loophole Exempting Investigation of Certain Goods Alleged to Be Derived from Forced Labor – Greater Enforcement in the Offing?”
- Speaking Engagements
- “IEEPA Tariffs After the Supreme Court Ruling in Learning Resources, Inc. v. Trump,” Practising Law Institute (PLI), March 24, 2026.
- “Looking Forward: Pending Policy Changes Shaping Location,” Site Selectors Guild Annual Conference Orlando, Fla, March 13, 2025.
Education
-
J.D., University of California, Irvine School of Law, 2014
B.A., University of California, Irvine, 2010
Admissions
-
District of Columbia
California
Courts
-
U.S. Court of Appeals for the Federal Circuit
U.S. Court of International Trade
Languages
-
Urdu