Press Release 04.11.24
Zach enables clients across multiple industries to engage in cross-border business, investment and trade by advising them on sanctions, export controls and national security matters.
Zach has an extensive knowledge of all aspects of U.S. international trade regulations. He leverages his past policy and national security experiences to counsel U.S., multinational and non-U.S. clients on navigating the constantly evolving U.S. sanctions programs and provides export-control regulatory guidance to manufacturers, energy companies, life sciences firms, the defense industry and multinational and emerging technology companies. He also represents U.S. and non-U.S. companies on all aspects of the U.S. national security review process before the Committee on Foreign Investment in the United States (CFIUS), including addressing structural and national security issues in the earliest stages of transaction planning.
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 United States 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.
Representative Experience
- 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.
- Advised European defense manufacturer on complex manufacturing license agreement, congressional notification requirements, and derivative data questions. Conduct export control diligence and strategic advice for major private equity investor involving acquisition transaction of defense services provider subject to ITAR Consent Agreement.
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- Successfully opposed tariffs on behalf of European crane manufacturer in Department of Commerce Section 232 investigation on mobile cranes.
- 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.
- Advised European defense manufacturer on complex manufacturing license agreement, congressional notification requirements and derivative data questions. Conduct export control diligence and strategic advice for major private equity investor involving acquisition transaction of defense services provider subject to ITAR Consent Agreement.
- 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.
- Represent executive chairman regarding compliance with Terms of Removal governing the lifting of OFAC sanctions on a Russian manufacturer.
- Export controls and sanctions counsel to global defense and vehicle manufacturer on a wide variety of military and dual-use export controls, sanctions and trade matters.
- 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.
- Counsel autonomous vehicle company in evaluating various public listing opportunities.
- Advise global aerospace manufacturer on complex FMS Third-Party Transfer transaction and PM/RSAT approval involving multiple countries.
- Advise nuclear manufacturer client regarding intersection of DOE Part 810, ITAR and EAR requirements.
- 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.
- 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.
- 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.
- Assisted a Chinese technology manufacturer in expanding its business footprint by providing global U.S. sanctions guidance and policy insight.
- Successfully represented a foreign private equity fund in the CFIUS review of its investment in a U.S. battery pack and electro-mechanical manufacturing business.
- Advised a U.S. defense contractor on ITAR and EAR classifications.
- Counseled a Swiss energy company on sectoral sanctions programs concerning proposed projects in Russia and Venezuela.
- Provided export-control guidance and licensing strategies for a leading spectrometer and x-ray manufacturing company.
- 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.
- Assisted a medical device manufacturer in navigating U.S. sanctions targeting Iran and Venezuela.
- Designed and implemented an export compliance program for a U.S. technology manufacturer.
- Represented several of the U.S.’s largest financial institutions in their investment in highly leveraged structured finance transactions.
- Reported on global counter-proliferation networks that utilized private industry to circumvent trade prohibitions.
Professional Highlights
- Recognized in Best Lawyers: Ones to Watch for Administrative/Regulatory Law (2024)
- “Symposium Review: Leakers, Whistleblowers & Traitors, An Evolving Paradigm,” Journal of National Security, Law & Policy (Volume 8, 2015)
- Speaking Engagements
- 22V Research, Webinar on Russian Sanctions and the Conflict in Ukraine, March 8, 2022
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- Firm Publications
- 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
- Biden Administration Announces Electric Vehicle Charging Action Plan to “Fast-Track” New Infrastructure Law Investments, Authors: Aimee P. Ghosh, Jorge Medina, Zachary C. Rozen, 01/10/2022
- President Biden’s “American Rescue Plan”, Authors: Elizabeth Vella Moeller, Craig J. Saperstein, Amanda G. Halter, Matthew Oresman, Zachary C. Rozen, 01/20/2021
- 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
- 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
- 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
- Supply Chain Threats and Cybersecurity Compliance Issues on the Horizon, Authors: Aaron R. Hutman, Dinesh Dharmadasa, Marques O. Peterson, Zachary C. Rozen, Brian P. Cruz, 07/15/2020
- 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
- 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, Authors: Steven L. Meltzer, Nancy A. Fischer, Matthew R. Rabinowitz, Joel M. Simon, Zachary C. Rozen, 06/04/2020
- 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
- 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
- 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
- OFAC Issues Sanctions Against Additional Rosneft Subsidiary and Amends Venezuelan General Licenses, Authors: Aaron R. Hutman, Stephanie Rosenberg, Zachary C. Rozen, 3/18/2020
- 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
- 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
Education
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J.D., Georgetown University Law Center, 2014
B.A., University of Richmond, 2007
American University of Sharjah, 2006
Admissions
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District of Columbia
Maryland
New York