Zachary C. Rozen

Prior to joining Pillsbury, Zach worked as an international trade and transactional attorney at another law firm. He also worked as a law clerk for the U.S. Senate Committee on Commerce, Science, and Transportation. Zach has a dynamic background prior to his work in the law, having served in the intelligence community and on staff for senior congressional leadership.

• Export Controls and Defense Technology Transfers
  • Assisted Finnish manufacturer of quantum-diluted refrigerators with trade compliance and government contracting diligence in connection with the acquisition and continue to counsel the two companies on post-closing trade compliance matters.
  • Developed trade compliance program for Australian defense firm and assisted in obtaining ITAR authorizations for defense articles.
  • Represented major U.S. defense company in obtaining ITAR authorization to engage in servicing of defense articles in the Middle East, as well as developing a trade regulatory, technology control and physical security compliance program.
  • Successfully obtained ITAR authorization on an expedited basis to deliver military training software to Ukraine on behalf of a defense technology startup.
  • Advised European defense manufacturer on obtaining a multiparty manufacturing license agreement and on congressional notification requirements and derivative data questions.
  • Conducted export control diligence and strategic advice for major private equity investor involving acquisition transaction of defense services provider subject to ITAR Consent Agreement.
  • Counsels a stratospheric UAV technology company with UK and U.S. export classifications and applying for UK and U.S. export licenses for controlled goods and technology.
  • Advise global aerospace manufacturer on complex FMS Third-Party Transfer transaction and PM/RSAT approval involving multiple countries.
  • Assist UK defense firm with mitigating foreign ownership, control and influence for U.S. government contracting opportunities and provide ITAR licensing strategies.
  • Counsel U.S.-based location and data technology company on export control and sanctions matters, including leading an internal review, preparing compliance manual, preparing and submitting CCATS to BIS for encryption items, and submission of voluntary self-disclosures to U.S. Departments of Commerce and Treasury.
  • 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.
  • Advises multinational aerospace component manufacturer on ITAR and EAR compliance and authorizations related to NASA Gateway Outpost.
  • Advised marine manufacturer on export control matters, including obtaining CJs and CCATS, and reviewing EAR and ITAR licenses in connection with its customers.
  • Conducted a corporate compliance assessment of a leading multinational pharmaceutical company, focusing on export-control policies and procedures, and designed and implemented an export compliance program.
• Regulation of Foreign Investment and National Security (CFIUS and FOCI-Mitigation)
  • Represented Finnish manufacturer of quantum-diluted refrigerators before CFIUS regarding its acquisition of U.S. developers of quantum-computing component.
  • Provided CFIUS guidance and advice to U.S. IT services and solutions company in its acquisition by U.S. semiconductor chips manufacturer.
  • Provided CFIUS and trade compliance advise to a U.S. software development company concerning a strategic investment from a global private equity firm.
  • Successfully navigated CFIUS and export control requirements in quantum computing sector for European company in acquisition of a U.S. manufacturer, including negotiating and implementation of mitigation agreement.
  • Advises major global nuclear and defense companies on starting new entities in the United States, including processes for new DCSA and DOE facility security clearances and associated FOCI mitigation.
  • Successfully obtained CFIUS clearance representing seller of power management integrated circuits for consumer electronics in connection with acquisition by Chinese-owned joint venture.
  • Provides CFIUS, FOCI-mitigation and global Foreign Direct Investment (FDI) guidance to national security-focused private equity fund in the acquisition of a global cybersecurity company from a Singapore state-owned entity.
  • Successfully obtained CFIUS clearance representing seller of power-management-integrated circuits for consumer electronics in connection with acquisition by Chinese-owned joint venture.
  • Advised private equity (PE) firm on portfolio review for outbound investment screening in anticipation of new rules and China Select Committee investigation.
  • Obtained CFIUS clearance for Korean and Japanese investors in various nuclear fusion technology companies.
  • Obtained CFIUS approval on behalf of a U.S. rocket company in connection with an investment by a Japanese firm.
  • Successfully represented a leading multinational life sciences and technology company in the CFIUS review of its acquisition of a Nasdaq-listed company that specializes in advanced materials innovation, with a focus on the semiconductor industry.
  • Act as CFIUS counsel for multiple venture capital funds, specializing in semiconductor investments.
  • Successfully represented U.S. satellite communications 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.
  • 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.
  • Act as CFIUS counsel in connection with photonics company’s $1.2 billion valuation merger with a Special Purpose Acquisition Company (SPAC).
  • Provide CFIUS counsel to venture capital firm in connection with a number of U.S. real estate investments.
  • Represent numerous U.S. artificial intelligence companies in their responses to CFIUS non-notified inquiries concerning minority investments by foreign parties.
• Economic Sanction and Embargoes
  • Advises European airlines, aircraft and engine lessors in addressing global sanctions on Russia insurance and litigation implications surrounding leased aircraft and engines, including BIS and OFAC licenses, andunblocking funds, as well as OFAC secondary sanctions and capital markets issues due to the involvement of sanctioned Russian financial institutions.
  • Advised Japanese industrial and energy services companies on Russia and Iran sanctions matters.
  • Advised multiple multinational companies in the banking, energy and investment sectors on U.S. and EU sanctions and export controls.
  • Assist German-based multinational financial services company with sale of Russian assets, which required secondary sanctions assessments, as well as BIS and OFAC authorizations.
  • Assisted a non-U.S. financial institution in the closing of an energy investment project in Russia by providing guidance concerning secondary sanctions and sectoral sanctions.
  • Assisted a Chinese technology manufacturer in expanding its business footprint by providing global U.S. sanctions guidance and policy insight.
  • Advised U.S. hedge fund with holdings in Russia and Europe on the short-term impact of Russia sanctions announcements and provided strategic sanctions guidance.
  • Counseled a Swiss energy company on sectoral sanctions programs concerning proposed projects in Russia and Venezuela.
  • Helped a European transportation firm successfully navigate U.S. secondary sanctions against Iran to enable it to invest in a major, cross-border transportation project in the Middle East.
  • Reported on global counter-proliferation networks that utilized private industry to circumvent trade prohibitions.
• Foreign Corrupt Practices Act (FCPA)
  • Counseled Japanese engineering company with global operations in the drafting and implementation of an anti-corruption compliance program.
  • Developed internal anti-corruption compliance program for information technology company with government contracting element.
  • Conducted FCPA and anti-corruption/anti-bribery diligence review and risk assessments in connection with multiple cross-border M&A transactions.

• “Symposium Review: Leakers, Whistleblowers and Traitors, An Evolving Paradigm,” Journal of National Security, Law & Policy (Volume 8, 2015)
• Speaking Engagements 
  • Federal Bar Association, Foreign Investment in the U.S.: CFIUS Compliance and Regulatory Trends, February 19, 2025.
  • 22V Research, Webinar on Russian Sanctions and the Conflict in Ukraine, March 8, 2022.
• Firm Publications
  • “847 Awaiting Takeoff: DCSA Issues Guidance on Expanded Scope of FOCI Assessments, May 13, 2025. Coauthor.
  • “President Trump Imposes Far-Reaching ‘Reciprocal’ Tariffs, Implements Tariffs on Automobiles and Closes De Minimis Loophole for Chinese Imports,” April 3, 2025. Coauthor.
  • “U.S. Tariffs on Non-USMCA Compliant Products Take Effect; Increased Tariff Rate on China Imposed,” May 5, 2025. Coauthor.
  • “Trump Administration Announces Sweeping Tariffs Under ‘Fair and Reciprocal Plan,’” February 14, 2025. Coauthor.
  • “The Trump Administration Reinstates and Expands Section 232 Tariffs on Steel and Aluminum,” February, 12, 2025. Coauthor.
  • “Trump 2.0: U.S. Tariffs on China Take Effect; Mexico and Canada Granted 30-Day Pause,” February 4, 2025. Coauthor.
  • “Trump 2.0: America First Trade Policy Takes Shape,” January 22, 2025. Coauthor.
  • “BIS Issues Interim Final Rule on Advanced Computing Integrated Circuits, Providing Long-Awaited Guidance on Due Diligence Procedures,” January 22, 2025. Coauthor.
  • “The Treasury Department Finalizes U.S. Outbound Investment Rules,” November 7, 2024. Coauthor.
  • “BIS Imposes New Export Controls on Quantum, Semiconductor and Additive Manufacturing Technologies,” September 11, 2024. Coauthor.
  • “U.S. Treasury Department Issues Proposed Rulemaking for Forthcoming Outbound Investment Program,” July 15, 2024. Coauthor.
  • “State Department Proposes Exempting Australia, UK from Certain Defense-Related Export Controls,” May 8, 2024. Coauthor.
  • “U.S. Increases Export Restrictions Against Nicaragua,” March 25, 2024. Coauthor.
  • “Key CHIPS Act Implementation Milestones and Opportunities for the Semiconductor Supply Chain,” February 29, 2024. Coauthor.
  • “BIS Issues Additional Enhancements to Voluntary Self-Disclosure Process,” February 6, 2024. Coauthor.
  • “U.S. Regulations on China: A Year-in-Review Series,” January 18, 2024. Coauthor.
  • “ISOO Guidance on Facility Security Clearances for Joint Ventures,” November 13, 2023. Coauthor.
  • “Closing the Loopholes: Additional Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items,” November 7, 2023. Coauthor.
  • “U.S. Government Imposes Second Round of Sanctions on Hamas,” November 1, 2023. Coauthor.
  • “OMB Final Guidance on Build America, Buy America Act Clarifies, Further Defines,” August 21, 2023. Coauthor.
  • “Long-Awaited Executive Order on Outbound Investment Issued: Regulatory Comment Process Commences in Advance of Implementation of Any New Rules,” August 10, 2023. Coauthor.
  • “All Eyes on China: Upcoming Restrictions on Outbound Investment,” July 25, 2023. Coauthor.
  • “The ‘Reverse’ CFIUS: An Outbound Investment Review Mechanism,” July 25, 2023. Coauthor.
  • “DOJ Action Highlights Dueling Export Control, Anti-Discrimination Risks,” May 22, 2023. Coauthor.
  • “The FCC and International Section 214 Authorizations,” May 4, 2023. Coauthor.
  • “DFARS Proposed Export Controls Rule Would Require Supplying DCMA with Copy of Relevant Export Authorizations,” April 7, 2023. Coauthor.
  • “The U.S. Department of Commerce’s New Proposed Rule Governing Restrictions on Chinese Investments,” April 4, 2023. Coauthor.
  • “IRA, CHIPS and IIJA Windows Open for New Federal Funding,” April 4, 2023. Coauthor.
  • “China Publishes Measures on Standard Contract for Cross-Border Transfer of Personal Information,” March 21, 2023. Coauthor.
  • “Russia Sanctions Year in Review: Impact on Energy Sector, ” February 14, 2023. Coauthor.
  • Russia Sanctions: A Year-in-Review Series, February 9, 2023. Coauthor.
  • “Commerce Issues Guidance on Recent Advanced Computing and Semiconductor Manufacturing Controls for China,” November 3, 2022. Coauthor.
  • “U.S. Commerce Department Imposes Sweeping China-Related Export Controls on Advanced Computing and Semiconductor Manufacturing Items,” October 14, 2022. Coauthor.
  • “Implementing the CTA: FinCEN Requires U.S. Companies to Report Beneficial Ownership Information and Protect Against Shell Company Misuse,” October 6, 2022. Coauthor.
  • “U.S. Commerce Department Implements Export Controls on Four New Emerging and Foundational Technologies,” August 17, 2022. Coauthor.
  • “State Department Issues Two Open General Licenses Authorizing Reexports and Retransfers of Certain Defense Articles for Australia, Canada and the UK,” July 27, 2022. Coauthor.
  • “Russia Takes Steps to Allow Use of Foreign-Held IP Rights Without Consent of the Rightsholder,” June 6, 2022. Coauthor.
  • “Landlords, Leases and Sanctioned Tenants,” April 1, 2022. Coauthor.
  • “Specially Designated Nationals as Tenants: How Landlords Can Be Impacted by Sanctions Against Russian Nationals,” March 31, 2022. Coauthor.
  • “Making Sense of Sanctions Versus SWIFT Delisting,” March 7, 2022. Coauthor.
  • “BIS Hits Russia and Belarus with Sweeping New Export Control Restrictions,” March 3, 2022. Coauthor.
  • “Russia Invades and the West Reacts: A Look at Russian Sanctions So Far,” February 25, 2022. Coauthor.
  • “Expanded U.S. Sanctions Targeting Russia’s Financial Sector,” February 24, 2022. Coauthor.
  • “Russia Invades and the West Reacts: U.S. Government Intensifies Sanctions and Export Controls Against Russia,” February 24, 2022. Coauthor.
  • “Further Sanctions Issued by the U.S. Government and Global Allies,” February 23, 2022. Coauthor.
  • “Initial Global Sanctions on Russia in Response to Events in Eastern Ukraine,” February 22, 2022. Coauthor.
  • “U.S. Government Takes First Steps Under Uyghur Forced Labor Prevention Act – Comment Period Opens and Published Questions Provide Initial Insights,” January 14, 2022. Coauthor.
  • “Biden Administration Announces Electric Vehicle Charging Action Plan to ‘Fast-Track’ New Infrastructure Law Investments,” January 10, 2022. Coauthor.
  • “Commerce Imposes New Export Controls on Cybersecurity Items and Adds a Corresponding License Exception,” October 21, 2021. Coauthor.
  • “Structuring M&A and Private Equity Deals: The CFIUS Challenge in Getting Deals Done,” September 7, 2021. Coauthor.
  • “Biden Administration Targets Global Corruption and Demonstrates Expansive Use of Magnitsky Sanctions,” July 29, 2021. Coauthor.
  • “Biden Administration Updates Framework for China-Related Investment Prohibitions and Expands the Scope of Restricted Chinese Companies,” July 7, 2021. Coauthor.
  • “New FCC Proposed Rules Would Prohibit Equipment Authorizations and Participation in License Auctions for Companies Posing National Security Risk,” June 19, 2021. Coauthor.
  • “Myanmar Update: U.S., UK and EU Continue to Expand Sanctions for Companies with Ties to the Military,” April 26, 2021. Coauthor.
  • “U.S. Announces Broad Array of New Russia Sanctions,” April 21, 2021. Coauthor.
  • “U.S. Government Continues to Ratchet Up Pressure Against Myanmar – The Latest Steps,” March 12, 2021. Coauthor.
  • “The Coup in Myanmar — U.S. Announces Initial Response with Targeted Sanctions and Export Controls,” February 12, 2021. Coauthor.
  • “President Biden Issues Order on ‘Made in America Laws,’” January 29, 2021. Coauthor.
  • “CBP’s Region-Wide WRO Escalates Pressure in China’s Xinjiang Region,” January 21, 2021. Coauthor.
  • “President Biden’s ‘American Rescue Plan,’” January 20, 2021. Coauthor.
  • “Commerce Department’s New ICTS Rule Raises Additional Considerations for Cross-Border Transactions,” January 20, 2021. Coauthor.
  • “U.S. Expands WROs in Xinjiang, Targeting Major Cotton Producer with Implications for Global Supply Chains,” December 14, 2020. Coauthor.
  • “U.S. Steps Up Pressure on Iran with Sanctions on Additional Financial Institutions and Continuation of Arms Embargo,” October 12, 2020. Coauthor.
  • “U.S. Commerce Department Implements Multilateral Controls on Six Emerging Technologies,” October 7, 2020. Coauthor.
  • “U.S. Commerce Department Announces Prohibited Transactions Related to WeChat and TikTok but Implementation Is Delayed,” September 20, 2020. Coauthor.
  • “CFIUS Issues Final Rule Basing Mandatory Declaration Requirement on U.S. Export Control Criteria,” September 16, 2020. Coauthor.
  • “Sudan Update: OFAC Issues Guidance Clarifying Status of U.S. Sanctions and Export Controls,” September 4, 2020. Coauthor.
  • “Executive Orders Target TikTok and WeChat Application Makers,” August 10, 2020. Coauthor.
  • “Heightened Risks and Plenty of Pitfalls: Avoiding Corruption During COVID-19,” July 28, 2020. Coauthor.
  • “Supply Chain Threats and Cybersecurity Compliance Issues on the Horizon,” July 15, 2020. Coauthor.
  • “U.S. Government Efforts to Eliminate Supply Chain Threats from China to Telecommunications Networks,” June 5, 2020. Coauthor.
  • “Comité de Inversión Extranjera de los Estados Unidos (CFIUS, por sus siglas en inglés) y Tecnologías Críticas: Implicaciones para los Sectores de Biotecnología y Ciencias de la Salud,” June 4, 2020. Coauthor.
  • “CFIUS Proposes Mandatory Declaration Requirement Based on U.S. Export Control Criteria,” May 22, 2020. Coauthor.
  • “BIS Amends Direct Product Rule to Target Huawei but Extends Huawei Temporary General License,” May 15, 2020. Coauthor.
  • “CFIUS and Critical Technologies: Implications for the Biotechnology and Life Sciences Sector,” May 5, 2020. Coauthor.
  • “New Filing Fees for CFIUS Notices Enter into Effect,” May 5, 2020. Coauthor.
  • “New Export Control Rules Confront Integration of Civilian and Military Technology Development in China, Russia and Venezuela,” April 30, 2020. Coauthor.
  • “New Export Control Rules Confront Integration of Civilian and Military Technology Development in China, Russia and Venezuela,” April 29, 2020. Coauthor.
  • “Examining CFIUS Implications for the Real Estate Market in the Post COVID-19 World,” April 22, 2020. Coauthor.
  • “Executive Order Establishes New Committee to Review Foreign Investment in Communications Companies,” April 10, 2020. Coauthor.
  • “OFAC Issues Sanctions Against Additional Rosneft Subsidiary and Amends Venezuelan General Licenses,” March 18, 2020. Coauthor.
  • “U.S. Expands Secondary Sanctions to Iran’s Industrial Sectors,” January 17, 2020. Coauthor.
  • “Key Takeaways from CFIUS Final Rules Implementing FIRRMA,” January 15, 2020. Coauthor.
  • “District Court Overturns OFAC Fine Against Exxon,” January 13, 2020. Coauthor.