Stephen R. Heifetz

Stephen R. Heifetz

Partner

Government Experience

Stephen previously served in the U.S. government as a CFIUS official, and in other national security positions at the CIA, Department of Homeland Security, and Department of Justice.
A Recognized CFIUS Practitioner

For two decades, Stephen has been involved in thousands of CFIUS matters. He helps U.S. companies and foreign investors assess CFIUS risks, draft risk-allocation language, respond to CFIUS inquiries and enforcement actions, make CFIUS filings, and obtain CFIUS clearances. He also serves as CFIUS counsel to the National Venture Capital Association and has been recognized as a leading CFIUS and national security expert by Chambers USA, Chambers Global, Foreign Investment Watch, and Washingtonian.
Anti-Money Laundering, Sanctions, and Other National Security Matters

Stephen has advised clients on regulatory compliance, investigations, and defense of government enforcement actions relating to anti-money laundering and beneficial ownership requirements, economic sanctions (including UN sanctions regimes), and an array of other national security matters.
A Thought Leader on CFIUS and National Security Issues

Stephen has published articles in many forums, including The New York Times, The Washington Post, Bloomberg, Semafor, Lawfare, The Hill, and Law360, and he speaks regularly on CFIUS and other national security topics.

Stephen Heifetz is a partner in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where he advises clients on laws and policies at the intersection of international business and national security. He has been a CFIUS practitioner for two decades, and has previously served for the U.S. government on the Committee on Foreign Investment in the United States (CFIUS). Stephen has advised the National Venture Capital Association (NVCA) on CFIUS policy issues, has been involved in thousands of CFIUS matters and has been recognized as a leading CFIUS and national security expert by Chambers USA, Chambers Global, Foreign Investment Watch, and Washingtonian. Chambers sources note Stephen is “extraordinarily knowledgeable, responsive, and offers great practical guidance.”

Stephen regularly helps U.S. companies and foreign investors determine whether to make a CFIUS filing, allocate CFIUS risk in transaction documents, navigate the CFIUS process, respond to CFIUS “non-notified” inquiries, and negotiate risk mitigation measures if needed to obtain CFIUS clearance.

Beyond CFIUS, Stephen advises clients on matters of legal compliance and political risk and defends companies facing investigations and government enforcement actions, often in the context of cross-border transactions and other activities. He represents clients with regard to anti-money laundering laws and beneficial ownership requirements administered by the Financial Crimes Enforcement Network (FinCEN) and other financial regulators, particularly laws pertaining to money transmitters and other money services businesses.

Additionally, Stephen advises on economic sanctions administered by the Office of Foreign Assets Control (OFAC) and by the UN Security Council, and has experience with anti-corruption and export control laws, with security screening rules applicable to visa applicants as well as airlines and other transportation companies, and with codes of conduct applicable to private security providers.

Prior to joining Wilson Sonsini, Stephen was a partner at a multinational law firm based in Washington, D.C., where he co-chaired that firm's international regulation and compliance group. From 2006 to 2010, he served as a senior official in the U.S. Department of Homeland Security's (DHS) Office of Policy Development. In this role, he served as DHS's daily representative to CFIUS and also worked with DHS's agencies—including the Transportation Security Administration, U.S. Customs and Border Protection, and U.S. Immigration and Customs Enforcement—to develop policies on a range of issues.

After finishing law school, Stephen worked as an attorney for the Central Intelligence Agency and later served as a trial attorney in the U.S. Department of Justice's Money Laundering and Asset Recovery Section.

Stephen has published articles in top business and legal media outlets, including The New York Times, The Washington Post, Bloomberg, Semafor, Lawfare, The Hill, and Law360. He also was previously an adjunct professor at Georgetown University Law Center.

Experience

Education

J.D., Georgetown University Law Center, 1996Magna Cum Laude; Order of the Coif; Senior Articles Editor, Georgetown Law Journal; Olin Fellow, Law and Economics
A.B., Stanford University, 1993With Honors
Visiting Student, Oxford University (Pembroke College), 1992

Associations and Memberships

Co-chair, 8th Annual National Conference on CFIUS, American Conference Institute

Honors

Named among Washingtonian’s 2024 Top Lawyers
Selected for inclusion among WWL’s 2025 “Thought Leaders – USA” and “Thought Leaders – M&A and Governance”
Recognized among top global CFIUS experts in the 2021-2024 “Top Advisors” lists by Foreign Investment Watch
Recognized among the country's top international trade CFIUS experts in the 2012-2024 editions of Chambers USA: America's Leading Lawyers for Business, where he is described as “very experienced and a clear conveyor of complex information and counsel" and “extraordinarily knowledgeable, responsive, and offers great practical guidance"
Recognized in the International Trade: CFIUS U.S. experts category in the 2015-2024 editions of Chambers Global, where he is known to be “intimately familiar with the entire CFIUS process” and “very experienced and a clear conveyor of complex information”
Honored among Washingtonian magazine's "Best Lawyers" in the national security category

Admissions

Bar of the District of Columbia
State Bar of Maryland

Credentials

Education

J.D., Georgetown University Law Center, 1996Magna Cum Laude; Order of the Coif; Senior Articles Editor, Georgetown Law Journal; Olin Fellow, Law and Economics
A.B., Stanford University, 1993With Honors
Visiting Student, Oxford University (Pembroke College), 1992

Associations and Memberships

Co-chair, 8th Annual National Conference on CFIUS, American Conference Institute

Honors

Named among Washingtonian’s 2024 Top Lawyers
Selected for inclusion among WWL’s 2025 “Thought Leaders – USA” and “Thought Leaders – M&A and Governance”
Recognized among top global CFIUS experts in the 2021-2024 “Top Advisors” lists by Foreign Investment Watch
Recognized among the country's top international trade CFIUS experts in the 2012-2024 editions of Chambers USA: America's Leading Lawyers for Business, where he is described as “very experienced and a clear conveyor of complex information and counsel" and “extraordinarily knowledgeable, responsive, and offers great practical guidance"
Recognized in the International Trade: CFIUS U.S. experts category in the 2015-2024 editions of Chambers Global, where he is known to be “intimately familiar with the entire CFIUS process” and “very experienced and a clear conveyor of complex information”
Honored among Washingtonian magazine's "Best Lawyers" in the national security category

Admissions

Bar of the District of Columbia
State Bar of Maryland

Select Publications

Co-author with A. Sebenius and G. Gruenspecht, "The New National Security Rules for Investing U.S. Capital," Wilson Sonsini Advisory, November 13, 2024
Author, “When ‘National Security’ Becomes a Political Excuse, We All Lose,” The Hill, October 26, 2024
Author, “National Security Regulation and the Decline of Cost-Benefit Analysis,” Council on Foreign Relations, October 10, 2024
Author, “Investment Screening: When 'Mandatory' Filings Might Not Be Mandatory,” 20Minds, September 23, 2024
Author, “CFIUS and the Cost of Risk Aversion,” Columbia FDI Perspectives (Columbia University), September 16, 2024
Co-author, “Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions,” Wilson Sonsini Alert, August 19, 2024
Co-author, “Proposed ‘Outbound Investment’ Regulations Target Transactions Involving PRC Semiconductor, Quantum, and AI Businesses,” Wilson Sonsini Alert, June 25, 2024
Co-author, “New Proposed CFIUS Rules Confirm a More Prosecutorial Regime, But to What End?” Wilson Sonsini Client Advisory, May 1, 2024
Author, "Advisor pens a CFIUS parable: 'The party house and the guard dog,'" Foreign Investment Watch, April 17, 2024
Author, “Yellen Could Stop U.S. Nativist Trajectory in Foreign Investment,” Bloomberg Law, September 12, 2023
Author, “CFIUS Clampdown Will Deter Allied-Country Investment,” Law360, July 25, 2023
Co-author with J. Gruenspecht, “’I See Dead Companies’: CFIUS Aims an FAQ at the Venture Capital Model,” Client Advisory, July 25, 2023
Co-author, “Considerations for M&A Transactions Involving Fintech Companies,” Wilson Sonsini Alert, June 15, 2023
Co-author with J. Davey, T. Jenkins, and B. Poellot, “Beware: Increasingly Aggressive Enforcement Actions in the Crypto Asset Industry Puts Companies on Notice,” Wilson Sonsini Alert, June 12, 2023
Co-author with J. Aiello LeBeau, J. Cheng, J. Davey, J. Hartwig, T. Jenkins, and A. Seymour, “OFAC Penalizes Another Crypto Asset Company for Sanctions Violations,” Wilson Sonsini Alert, May 11, 2023
Co-author, “Treasury Risk Assessment Emphasizes That Decentralized Crypto Companies Have AML and Sanctions Compliance Obligations,” Wilson Sonsini Alert, April 25, 2023
Co-author, “National Security Regulations 2022 Year in Review,” Wilson Sonsini newsletter, February 14, 2023
Author, “The U.S. Government Should Try Harder to Minimize Costs of China Defensive Measures,” Lawfare, February 13, 2023
Opinion Contributor, “Tightening Foreign Investment Screening Undermines National Security,” The Hill, January 18, 2023
Guest Columnist, “Stephen Heifetz: What I See as a CFIUS Lawyer,” Semafor, January 13, 2023
Co-author with J. Cheng, J. Hartwig, and T. Jenkins, “Coinbase Agrees to Pay $100 Million and Improve Compliance Program as Regulators Continue Scrutiny of Crypto Asset Companies,” Wilson Sonsini Alert, January 12, 2023
Co-author with M. Casey, J. Hartwig, T. Jenkins, and A. Seymour, “Crypto Exchange Agrees to Pay More Than $362,000 to Settle Alleged Sanctions Violations,” Wilson Sonsini Advisory, December 14, 2022
Co-author with J. Gruenspecht and J. Lynch, “CFIUS Guidelines: Betwixt and Between,” Wilson Sonsini Advisory, November 16, 2022
Co-author with T. Jenkins, M. Casey, and J. Davey, “Final Regulations on Beneficial Ownership Will Require ‘Tens of Millions’ of Legal Entities to File Reports,” Wilson Sonsini Alert, October 4, 2022
Co-author with N. Dhir, J. Gruenspecht, and K. Millard, "President Biden’s Executive Order on CFIUS Likely to Yield Incremental Tightening ," Wilson Sonsini Alert, September 20, 2022
Co-author with J. Davey and T. Jenkins, "Money Services Businesses Penalized for Failure to Adopt Robust Anti-Money Laundering Practices," Wilson Sonsini Alert, August 18, 2022
Co-author with J. Gruenspecht and N. Dhir, "A Tale of Two Filers: CFIUS Report Touts Efficiency, Also Indicates CFIUS Failed to Meet Statutory Deadlines for a Large Percentage of Filed Notices," Wilson Sonsini Bylined Article, August 17, 2022
Guest Opinion Columnist, "It's all China and Russia: CFIUS expert says it's tiem to 'get real,'" Foreign Investment Watch, August 13, 2022
Co-author with J. Gruenspecht, "Proposed Legislation Seeks to Create 'Reverse CFIUS': National Security Review of Outbound Activity Benefiting Entities or Countries of Concern," Wilson Sonsini Advisory, August 8, 2022
Co-author with M. Casey and J. Gruenspecht, "BEIS Blocks First Transaction Under the UK’s National Security and Investment Act," Wilson Sonsini Alert, August 1, 2022
Co-author with T. Jenkins, "Headed to the Metaverse? Be 'The One' to Minimize Money Laundering Risk," Wilson Sonsini Advisory, July 14, 2022
Co-author with M. Casey and J. Gruenspecht, "BEIS Publishes First Annual Report Regarding the UK's National Security and Investment Act," Wilson Sonsini Alert, July 5, 2022
Co-author with A. Caiazza, J. Kaplan, J. Hartwig, J. Davey, and T. Jenkins, "No Foolish Transactions: A Few Guidelines for NFT Marketplace Participants to Mitigate Anti-Money Laundering Risks," Wilson Sonsini Advisory, May 23, 2022
Co-author with J. Davey, N. Dhir, and J. Gruenspecht, “CFIUS Rules: A Crash Course in Assessing and Navigating Risk,” Practical Guidance, March 2022
Co-author with M. Alioto, A. Caiazza, and T. Jenkins, "President Biden Signs Executive Order on Ensuring Responsible Development of Digital Assets," Wilson Sonsini Advisory, March 15, 2022
Co-author with T. Jenkins and J. Kaplan, "Is Regulation of NFTs to Combat Financial Crime on the Horizon?" Wilson Sonsini Alert, February 23, 2022
Author, “Enhanced CFIUS Rules Have Lawyers Pushing Benefits of Foreign Investment,” The National Law Journal, February 23, 2022
Co-author with J. Aiello LeBeau, M. Casey, J. Hartwig, and A. Seymour, "CJEU Publishes Judgment Interpreting the EU's Blocking Regulation," Wilson Sonsini Alert, February 3, 2022
Co-author with M. Casey and J. Gruenspecht, "The UK’s National Security and Investment Act Now Fully in Force," Wilson Sonsini Alert, January 4, 2022
Co-author with M. Casey, J. Davey, J. Gruenspecht, and T. Jenkins, "New Rules Will Require Beneficial Ownership Reporting to Federal Regulators by U.S. and Foreign Corporations, LLCs, and Other Legal Entities," Wilson Sonsini Alert, January 4, 2022
Co-author with M. Casey, J. Davey, J. Hartwig, and T. Jenkins, "New OFAC Guidance Raises the Stakes for Crypto Industry," Wilson Sonsini Alert, October 20, 2021
Co-author with J. Davey and T. Jenkins, "National Cryptocurrency Enforcement Team Turns Up the Crypto Heat," Wilson Sonsini Alert, October 18, 2021
Author, “Policing of foreign tech investment in the US is broken. Here’s how to fix it.” Protocol, October 4, 2021
Co-author with J. Davey and J. Kaplan, "Anonymity Becomes Passé: U.S. Government Moves to Require Ownership Information for Corporations, LLCs, and Others," Wilson Sonsini Alert, April 15, 2021
Co-author with S. Cowell and J. Gruenspecht, "Companies That Procure IT Products or Services from China, Russia, and Certain Other "Adversary" Nations May Face New National Security Questions Under the Now-Effective "ICTS" Rule," Wilson Sonsini Alert, March 25, 2021
Co-author with A.J. Bender, S. Cowell, and J. Gruenspecht "A National Security Parting Gift to the New Administration: Additional Burdens for IT Supply Chains and Infrastructure as a Service," Wilson Sonsini Alert, January 26, 2021
Co-author with J. Kaplan, J.E. Krosnicki, and C. Wang, "MSB or Not MSB? That Is the Question (for Determining Applicability of Anti-Money Laundering Rules)," Wilson Sonsini Alert, January 25, 2021
Co-author, National Security Regulations 2020 Year in Review, Wilson Sonsini, December 17, 2020
Co-author with J. Kaplan, "New Anti-Money Laundering Legislation Will Create Significant Transparency Compliance Requirements for Businesses and Investors," Wilson Sonsini Alert, December 14, 2020
Co-author with J.F. Gruenspecht, J.R. Davey, and N. Dhir, "CFIUS After FIRRMA Implementation: A Crash Course in Assessing and Navigating Risk," Wilson Sonsini Alert, October 15, 2020
Co-author with J.I. Aiello LeBeau, A.E. Seymour, M.B. Mannino, and J.F. Gruenspecht, "As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat," Wilson Sonsini Alert, September 21, 2020
Co-author with A.E. Seymour and J.F. Gruenspecht, "Executive Orders on TikTok and WeChat: Ambiguity and a Few Other Takeaways," Wilson Sonsini Alert, August 7, 2020
Co-author with J.F. Gurenspecht, M.B. Mannino, and N. Dhir, "Buyer Beware: Stepped Up Enforcement and Monitoring by CFIUS," Wilson Sonsini Alert, June 22, 2020
Co-author with J.F. Gruenspecht, M.B. Mannino, and S. Cowell, "CFIUS Serves Up Proposed Changes to Mandatory Filing Rules: Bon Appétit!" Wilson Sonsini Alert, May 28, 2020
Co-author with J.E. Krosnicki, "How Gaming Companies Can Become Inadvertent Money Services Businesses," Wilson Sonsini Alert, May 27, 2020
Co-author with J.F. Gruenspecht and J.R. Davey, "CFIUS Filing Fees Finalized: Prepare to Pay (or Not)," Wilson Sonsini Alert, April 30, 2020
Co-author with J.F. Gruenspecht, J. Lynch, and S. Cowell, "The New National Security Regulatory: Team Telecom Becomes CAFPUSTSS (?) and Has a Big First Week," Wilson Sonsini Alert, April 22, 2020
Co-author with M.B. Mannino, J.F. Gruenspecht, and J.R. Davey, "CFIUS Update: COVID-19 Slowdown, Enforcement Uptick, and Jurisdictional Dismissals," Wilson Sonsini Alert, April 15, 2020
Co-author with J.F. Gruenspecht and J.R. Davey, "Fees and Loathing at CFIUS: The Committee Imposes Filing Fees, Forces Divestment, and Reportedly Blocks Another Big Deal," Wilson Sonsini Alert, March 9, 2020
Co-author with J. Gruenspecht and M. Mannino, “What Technology Businesses and Investors Should Know About the New CFIUS Rules," WSGR Client Advisory, January 16, 2020
Co-author with J. Gruenspecht and M. Mannino, “Key Takeaways from the New Proposed CFIUS Rules," WSGR Client Advisory, September 24, 2019
Co-author with J. Gruenspecht and M. Mannino, “After Calm Summer, Expect CFIUS Landscape To Erupt,” Law360, August 28, 2019
Co-author with J. Gruenspecht, "CFIUS 2.0 Roundup: The Pilot Program, The Shoulder Shrug," Law360, March 29, 2019
Co-author with J. Gruenspecht, M. Mannino, and B. George, "CFIUS Past, Present, and Future: A 2018 CFIUS Carol," WSGR CFIUS 2018 Year in Review, December 20, 2018
Co-author with J. Gruenspecht and M. Mannino, "Five Questions to Determine If You Have a CFIUS Filing Requirement," WSGR Client Advisory, October 18, 2018
Co-author with J. Gruenspecht and M. Mannino, "Three-and-a-Half CFIUS Issues Needing Immediate Attention: Why Thinking 'Big Whoop' Could Lead to Big Trouble," WSGR Client Advisory, August 13, 2018
Co-author with J. Gruenspecht, "CFIUS Reform Legislation: Four Early Questions Investors and Companies Need to Ask," WSGR Client Advisory, July 26, 2018
Co-author with J. Gruenspecht, M. Mannino, and B. George, "CFIUS Legislation and Chinese Foreign Investment Restrictions: Status Update and Practical Implications," WSGR Client Advisory, May 29, 2018
Co-author, "Anti-Money Laundering Obligations for Virtual Currency Companies," WSGR Client Advisory, April 2, 2018
Co-author with J. Gruenspecht, "How the CFIUS Calculus Continues to Change," Law360, March 1, 2018
Co-author with B. George and M. Mannino, "A Momentous Year For CFIUS: Part 2," Law360, January 16, 2018
Co-author with B. George and M. Mannino, "A Momentous Year For CFIUS: Part 1," Law360, January 12, 2018
"The CFIUS Calculus Has Changed—In More Ways than One," Law360, July 19, 2017
Co-author with P. Jeydel, "Time to Finally End the Cuba Embargo," The Hill, October 27, 2016
Co-author with A. Early, "The Right Time to Make a CFIUS Filing," Law360, September 27, 2016
"Sanctions Worked, Congress. Let Them Die," The New York Times, August 4, 2015
Co-author with E. Sherwood, "Those Other Economic Sanctions: Section 311 Special Measures," The Banking Law Journal, September 2014
"How to Keep Terrorism Grounded," The New York Times, November 1, 2010
"The Risk of Too Much Oversight," The New York Times, July 21, 2008
"A Wasteful Pursuit of Terrorist Money," The Washington Post, August 24, 2005

Select Speaking Engagements

Guest Speaker, "Stephen Heifetz: The Fight Over the Future of U.S. Steel," Inside Sources Podcast, KSL Newsradio, October 31, 2024
Speaker, “National Security Investment Restrictions Go Global: CFIUS Updates for VCs,” National Venture Capital Association, September 28, 2022
Speaker, “The Expansion of Investment Screening: Implications for Business and Investors,” Committee on Foreign Relations, March 24, 2022
Speaker, “How to Adapt to the New National Security Review Law for Foreign Investment in US Technology Companies,” The Japan Society of Northern California and JETRO, Webinar, October 7, 2021
Speaker, "U.S. and UK Venture Investment and National Security: A Joint Discussion with CFIUS and BEIS," Wilson Sonsini Events, April 21, 2021
Speaker, "Navigating the Growing Anti-Money Laundering Thicket for Technology Companies," Wilson Sonsini Events, February 24, 2021
Speaker, "M&A and Regulatory Considerations Under a Biden Administration," Wilson Sonsini Events, December 9, 2020
Speaker, "CFIUS and China Foreign Investment," Asia Society Northern California Webcast, November 19, 2020
Speaker, "CFIUS Rule Updates: What Technology Businesses and Investors Should Know," Osage University Partners Webinar, October 27, 2020
Speaker, "CFIUS After FIRRMA" Webcast, DealLawyers.com, October 6, 2020
Speaker, "Update on CFIUS and FIRRMA," 99th Annual AAEI Conference & Expo, August 26, 2020
Speaker, "The New CFIUS Rules: What Do Technology Businesses and Investors Need to Know?" Wilson Sonsini Events, March 5, 2020
Speaker, "CFIUS Lounge Audio Conference," Wilson Sonsini Events, February 11, 2020
Speaker, "CFIUS Final Rules & VC Impact," NVCA, January 28, 2020
Speaker, "CFIUS Status: Final Stages of FIRRMA Implementation, Early in the Enforcement Era," Wilson Sonsini Webinar Series: Regulatory Compliance Considerations in Today's Global Economy, June 25, 2020
Moderator, “Fireside Chat: CFIUS discussion with Tom Feddo, Department of the Treasury Assistant Secretary for Investment Security,” Emerging Technology Meets National Security Conference, November 7, 2019
Speaker, “New Proposed CFIUS Rules and their Implications for Venture Capital,” National Venture Capital Association, October 4, 2019
Speaker, “To File or Not to File – You Be the Judge: Making the Decision of Whether or Not to File a Voluntary Notice for CFIUS Review in the Context of Future Transactions with China,” 5th National Conference on CFIUS & Team Telecom, American Conference Institute, April 24, 2019
Speaker, “Challenges of Venture Investment in China and Abroad: Creative and Trendy Business Models,” China Healthcare Investment Conference (CHIC), March 26, 2019
Speaker, "Pre-Acquisition Planning: How Stakeholders Are Now Minimizing Known and Unknown Risks through Contractual, Financial, and Cybersecurity Measures," 4th National Forum on CFIUS and Team Telecom, American Conference Institute, January 31, 2018
CFIUS panel, Elevation Securities Seminar, September 14, 2017
CFIUS Session, FBI Information Sharing Initiative Conference, April 24, 2017
Foreign Investment Reviews and the New Administration, U.S.-China Business Council, March 23, 2017
"Foreign Investment in the U.S.: Obtaining CFIUS Approval," J.P. Morgan Special Situations Investor Forum, March 13, 2017
"A Contractor's Guide to Doing Business with the Department of Homeland Security," Federal Publications Seminars, November 9, 2016
"The U.S. Contractor's Guide to Doing Business in Israel," Federal Publications Seminars, July 27, 2016

Insights

Select Publications

Co-author with A. Sebenius and G. Gruenspecht, "The New National Security Rules for Investing U.S. Capital," Wilson Sonsini Advisory, November 13, 2024
Author, “When ‘National Security’ Becomes a Political Excuse, We All Lose,” The Hill, October 26, 2024
Author, “National Security Regulation and the Decline of Cost-Benefit Analysis,” Council on Foreign Relations, October 10, 2024
Author, “Investment Screening: When 'Mandatory' Filings Might Not Be Mandatory,” 20Minds, September 23, 2024
Author, “CFIUS and the Cost of Risk Aversion,” Columbia FDI Perspectives (Columbia University), September 16, 2024
Co-author, “Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions,” Wilson Sonsini Alert, August 19, 2024
Co-author, “Proposed ‘Outbound Investment’ Regulations Target Transactions Involving PRC Semiconductor, Quantum, and AI Businesses,” Wilson Sonsini Alert, June 25, 2024
Co-author, “New Proposed CFIUS Rules Confirm a More Prosecutorial Regime, But to What End?” Wilson Sonsini Client Advisory, May 1, 2024
Author, "Advisor pens a CFIUS parable: 'The party house and the guard dog,'" Foreign Investment Watch, April 17, 2024
Author, “Yellen Could Stop U.S. Nativist Trajectory in Foreign Investment,” Bloomberg Law, September 12, 2023
Author, “CFIUS Clampdown Will Deter Allied-Country Investment,” Law360, July 25, 2023
Co-author with J. Gruenspecht, “’I See Dead Companies’: CFIUS Aims an FAQ at the Venture Capital Model,” Client Advisory, July 25, 2023
Co-author, “Considerations for M&A Transactions Involving Fintech Companies,” Wilson Sonsini Alert, June 15, 2023
Co-author with J. Davey, T. Jenkins, and B. Poellot, “Beware: Increasingly Aggressive Enforcement Actions in the Crypto Asset Industry Puts Companies on Notice,” Wilson Sonsini Alert, June 12, 2023
Co-author with J. Aiello LeBeau, J. Cheng, J. Davey, J. Hartwig, T. Jenkins, and A. Seymour, “OFAC Penalizes Another Crypto Asset Company for Sanctions Violations,” Wilson Sonsini Alert, May 11, 2023
Co-author, “Treasury Risk Assessment Emphasizes That Decentralized Crypto Companies Have AML and Sanctions Compliance Obligations,” Wilson Sonsini Alert, April 25, 2023
Co-author, “National Security Regulations 2022 Year in Review,” Wilson Sonsini newsletter, February 14, 2023
Author, “The U.S. Government Should Try Harder to Minimize Costs of China Defensive Measures,” Lawfare, February 13, 2023
Opinion Contributor, “Tightening Foreign Investment Screening Undermines National Security,” The Hill, January 18, 2023
Guest Columnist, “Stephen Heifetz: What I See as a CFIUS Lawyer,” Semafor, January 13, 2023
Co-author with J. Cheng, J. Hartwig, and T. Jenkins, “Coinbase Agrees to Pay $100 Million and Improve Compliance Program as Regulators Continue Scrutiny of Crypto Asset Companies,” Wilson Sonsini Alert, January 12, 2023
Co-author with M. Casey, J. Hartwig, T. Jenkins, and A. Seymour, “Crypto Exchange Agrees to Pay More Than $362,000 to Settle Alleged Sanctions Violations,” Wilson Sonsini Advisory, December 14, 2022
Co-author with J. Gruenspecht and J. Lynch, “CFIUS Guidelines: Betwixt and Between,” Wilson Sonsini Advisory, November 16, 2022
Co-author with T. Jenkins, M. Casey, and J. Davey, “Final Regulations on Beneficial Ownership Will Require ‘Tens of Millions’ of Legal Entities to File Reports,” Wilson Sonsini Alert, October 4, 2022
Co-author with N. Dhir, J. Gruenspecht, and K. Millard, "President Biden’s Executive Order on CFIUS Likely to Yield Incremental Tightening ," Wilson Sonsini Alert, September 20, 2022
Co-author with J. Davey and T. Jenkins, "Money Services Businesses Penalized for Failure to Adopt Robust Anti-Money Laundering Practices," Wilson Sonsini Alert, August 18, 2022
Co-author with J. Gruenspecht and N. Dhir, "A Tale of Two Filers: CFIUS Report Touts Efficiency, Also Indicates CFIUS Failed to Meet Statutory Deadlines for a Large Percentage of Filed Notices," Wilson Sonsini Bylined Article, August 17, 2022
Guest Opinion Columnist, "It's all China and Russia: CFIUS expert says it's tiem to 'get real,'" Foreign Investment Watch, August 13, 2022
Co-author with J. Gruenspecht, "Proposed Legislation Seeks to Create 'Reverse CFIUS': National Security Review of Outbound Activity Benefiting Entities or Countries of Concern," Wilson Sonsini Advisory, August 8, 2022
Co-author with M. Casey and J. Gruenspecht, "BEIS Blocks First Transaction Under the UK’s National Security and Investment Act," Wilson Sonsini Alert, August 1, 2022
Co-author with T. Jenkins, "Headed to the Metaverse? Be 'The One' to Minimize Money Laundering Risk," Wilson Sonsini Advisory, July 14, 2022
Co-author with M. Casey and J. Gruenspecht, "BEIS Publishes First Annual Report Regarding the UK's National Security and Investment Act," Wilson Sonsini Alert, July 5, 2022
Co-author with A. Caiazza, J. Kaplan, J. Hartwig, J. Davey, and T. Jenkins, "No Foolish Transactions: A Few Guidelines for NFT Marketplace Participants to Mitigate Anti-Money Laundering Risks," Wilson Sonsini Advisory, May 23, 2022
Co-author with J. Davey, N. Dhir, and J. Gruenspecht, “CFIUS Rules: A Crash Course in Assessing and Navigating Risk,” Practical Guidance, March 2022
Co-author with M. Alioto, A. Caiazza, and T. Jenkins, "President Biden Signs Executive Order on Ensuring Responsible Development of Digital Assets," Wilson Sonsini Advisory, March 15, 2022
Co-author with T. Jenkins and J. Kaplan, "Is Regulation of NFTs to Combat Financial Crime on the Horizon?" Wilson Sonsini Alert, February 23, 2022
Author, “Enhanced CFIUS Rules Have Lawyers Pushing Benefits of Foreign Investment,” The National Law Journal, February 23, 2022
Co-author with J. Aiello LeBeau, M. Casey, J. Hartwig, and A. Seymour, "CJEU Publishes Judgment Interpreting the EU's Blocking Regulation," Wilson Sonsini Alert, February 3, 2022
Co-author with M. Casey and J. Gruenspecht, "The UK’s National Security and Investment Act Now Fully in Force," Wilson Sonsini Alert, January 4, 2022
Co-author with M. Casey, J. Davey, J. Gruenspecht, and T. Jenkins, "New Rules Will Require Beneficial Ownership Reporting to Federal Regulators by U.S. and Foreign Corporations, LLCs, and Other Legal Entities," Wilson Sonsini Alert, January 4, 2022
Co-author with M. Casey, J. Davey, J. Hartwig, and T. Jenkins, "New OFAC Guidance Raises the Stakes for Crypto Industry," Wilson Sonsini Alert, October 20, 2021
Co-author with J. Davey and T. Jenkins, "National Cryptocurrency Enforcement Team Turns Up the Crypto Heat," Wilson Sonsini Alert, October 18, 2021
Author, “Policing of foreign tech investment in the US is broken. Here’s how to fix it.” Protocol, October 4, 2021
Co-author with J. Davey and J. Kaplan, "Anonymity Becomes Passé: U.S. Government Moves to Require Ownership Information for Corporations, LLCs, and Others," Wilson Sonsini Alert, April 15, 2021
Co-author with S. Cowell and J. Gruenspecht, "Companies That Procure IT Products or Services from China, Russia, and Certain Other "Adversary" Nations May Face New National Security Questions Under the Now-Effective "ICTS" Rule," Wilson Sonsini Alert, March 25, 2021
Co-author with A.J. Bender, S. Cowell, and J. Gruenspecht "A National Security Parting Gift to the New Administration: Additional Burdens for IT Supply Chains and Infrastructure as a Service," Wilson Sonsini Alert, January 26, 2021
Co-author with J. Kaplan, J.E. Krosnicki, and C. Wang, "MSB or Not MSB? That Is the Question (for Determining Applicability of Anti-Money Laundering Rules)," Wilson Sonsini Alert, January 25, 2021
Co-author, National Security Regulations 2020 Year in Review, Wilson Sonsini, December 17, 2020
Co-author with J. Kaplan, "New Anti-Money Laundering Legislation Will Create Significant Transparency Compliance Requirements for Businesses and Investors," Wilson Sonsini Alert, December 14, 2020
Co-author with J.F. Gruenspecht, J.R. Davey, and N. Dhir, "CFIUS After FIRRMA Implementation: A Crash Course in Assessing and Navigating Risk," Wilson Sonsini Alert, October 15, 2020
Co-author with J.I. Aiello LeBeau, A.E. Seymour, M.B. Mannino, and J.F. Gruenspecht, "As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat," Wilson Sonsini Alert, September 21, 2020
Co-author with A.E. Seymour and J.F. Gruenspecht, "Executive Orders on TikTok and WeChat: Ambiguity and a Few Other Takeaways," Wilson Sonsini Alert, August 7, 2020
Co-author with J.F. Gurenspecht, M.B. Mannino, and N. Dhir, "Buyer Beware: Stepped Up Enforcement and Monitoring by CFIUS," Wilson Sonsini Alert, June 22, 2020
Co-author with J.F. Gruenspecht, M.B. Mannino, and S. Cowell, "CFIUS Serves Up Proposed Changes to Mandatory Filing Rules: Bon Appétit!" Wilson Sonsini Alert, May 28, 2020
Co-author with J.E. Krosnicki, "How Gaming Companies Can Become Inadvertent Money Services Businesses," Wilson Sonsini Alert, May 27, 2020
Co-author with J.F. Gruenspecht and J.R. Davey, "CFIUS Filing Fees Finalized: Prepare to Pay (or Not)," Wilson Sonsini Alert, April 30, 2020
Co-author with J.F. Gruenspecht, J. Lynch, and S. Cowell, "The New National Security Regulatory: Team Telecom Becomes CAFPUSTSS (?) and Has a Big First Week," Wilson Sonsini Alert, April 22, 2020
Co-author with M.B. Mannino, J.F. Gruenspecht, and J.R. Davey, "CFIUS Update: COVID-19 Slowdown, Enforcement Uptick, and Jurisdictional Dismissals," Wilson Sonsini Alert, April 15, 2020
Co-author with J.F. Gruenspecht and J.R. Davey, "Fees and Loathing at CFIUS: The Committee Imposes Filing Fees, Forces Divestment, and Reportedly Blocks Another Big Deal," Wilson Sonsini Alert, March 9, 2020
Co-author with J. Gruenspecht and M. Mannino, “What Technology Businesses and Investors Should Know About the New CFIUS Rules," WSGR Client Advisory, January 16, 2020
Co-author with J. Gruenspecht and M. Mannino, “Key Takeaways from the New Proposed CFIUS Rules," WSGR Client Advisory, September 24, 2019
Co-author with J. Gruenspecht and M. Mannino, “After Calm Summer, Expect CFIUS Landscape To Erupt,” Law360, August 28, 2019
Co-author with J. Gruenspecht, "CFIUS 2.0 Roundup: The Pilot Program, The Shoulder Shrug," Law360, March 29, 2019
Co-author with J. Gruenspecht, M. Mannino, and B. George, "CFIUS Past, Present, and Future: A 2018 CFIUS Carol," WSGR CFIUS 2018 Year in Review, December 20, 2018
Co-author with J. Gruenspecht and M. Mannino, "Five Questions to Determine If You Have a CFIUS Filing Requirement," WSGR Client Advisory, October 18, 2018
Co-author with J. Gruenspecht and M. Mannino, "Three-and-a-Half CFIUS Issues Needing Immediate Attention: Why Thinking 'Big Whoop' Could Lead to Big Trouble," WSGR Client Advisory, August 13, 2018
Co-author with J. Gruenspecht, "CFIUS Reform Legislation: Four Early Questions Investors and Companies Need to Ask," WSGR Client Advisory, July 26, 2018
Co-author with J. Gruenspecht, M. Mannino, and B. George, "CFIUS Legislation and Chinese Foreign Investment Restrictions: Status Update and Practical Implications," WSGR Client Advisory, May 29, 2018
Co-author, "Anti-Money Laundering Obligations for Virtual Currency Companies," WSGR Client Advisory, April 2, 2018
Co-author with J. Gruenspecht, "How the CFIUS Calculus Continues to Change," Law360, March 1, 2018
Co-author with B. George and M. Mannino, "A Momentous Year For CFIUS: Part 2," Law360, January 16, 2018
Co-author with B. George and M. Mannino, "A Momentous Year For CFIUS: Part 1," Law360, January 12, 2018
"The CFIUS Calculus Has Changed—In More Ways than One," Law360, July 19, 2017
Co-author with P. Jeydel, "Time to Finally End the Cuba Embargo," The Hill, October 27, 2016
Co-author with A. Early, "The Right Time to Make a CFIUS Filing," Law360, September 27, 2016
"Sanctions Worked, Congress. Let Them Die," The New York Times, August 4, 2015
Co-author with E. Sherwood, "Those Other Economic Sanctions: Section 311 Special Measures," The Banking Law Journal, September 2014
"How to Keep Terrorism Grounded," The New York Times, November 1, 2010
"The Risk of Too Much Oversight," The New York Times, July 21, 2008
"A Wasteful Pursuit of Terrorist Money," The Washington Post, August 24, 2005

Select Speaking Engagements

Guest Speaker, "Stephen Heifetz: The Fight Over the Future of U.S. Steel," Inside Sources Podcast, KSL Newsradio, October 31, 2024
Speaker, “National Security Investment Restrictions Go Global: CFIUS Updates for VCs,” National Venture Capital Association, September 28, 2022
Speaker, “The Expansion of Investment Screening: Implications for Business and Investors,” Committee on Foreign Relations, March 24, 2022
Speaker, “How to Adapt to the New National Security Review Law for Foreign Investment in US Technology Companies,” The Japan Society of Northern California and JETRO, Webinar, October 7, 2021
Speaker, "U.S. and UK Venture Investment and National Security: A Joint Discussion with CFIUS and BEIS," Wilson Sonsini Events, April 21, 2021
Speaker, "Navigating the Growing Anti-Money Laundering Thicket for Technology Companies," Wilson Sonsini Events, February 24, 2021
Speaker, "M&A and Regulatory Considerations Under a Biden Administration," Wilson Sonsini Events, December 9, 2020
Speaker, "CFIUS and China Foreign Investment," Asia Society Northern California Webcast, November 19, 2020
Speaker, "CFIUS Rule Updates: What Technology Businesses and Investors Should Know," Osage University Partners Webinar, October 27, 2020
Speaker, "CFIUS After FIRRMA" Webcast, DealLawyers.com, October 6, 2020
Speaker, "Update on CFIUS and FIRRMA," 99th Annual AAEI Conference & Expo, August 26, 2020
Speaker, "The New CFIUS Rules: What Do Technology Businesses and Investors Need to Know?" Wilson Sonsini Events, March 5, 2020
Speaker, "CFIUS Lounge Audio Conference," Wilson Sonsini Events, February 11, 2020
Speaker, "CFIUS Final Rules & VC Impact," NVCA, January 28, 2020
Speaker, "CFIUS Status: Final Stages of FIRRMA Implementation, Early in the Enforcement Era," Wilson Sonsini Webinar Series: Regulatory Compliance Considerations in Today's Global Economy, June 25, 2020
Moderator, “Fireside Chat: CFIUS discussion with Tom Feddo, Department of the Treasury Assistant Secretary for Investment Security,” Emerging Technology Meets National Security Conference, November 7, 2019
Speaker, “New Proposed CFIUS Rules and their Implications for Venture Capital,” National Venture Capital Association, October 4, 2019
Speaker, “To File or Not to File – You Be the Judge: Making the Decision of Whether or Not to File a Voluntary Notice for CFIUS Review in the Context of Future Transactions with China,” 5th National Conference on CFIUS & Team Telecom, American Conference Institute, April 24, 2019
Speaker, “Challenges of Venture Investment in China and Abroad: Creative and Trendy Business Models,” China Healthcare Investment Conference (CHIC), March 26, 2019
Speaker, "Pre-Acquisition Planning: How Stakeholders Are Now Minimizing Known and Unknown Risks through Contractual, Financial, and Cybersecurity Measures," 4th National Forum on CFIUS and Team Telecom, American Conference Institute, January 31, 2018
CFIUS panel, Elevation Securities Seminar, September 14, 2017
CFIUS Session, FBI Information Sharing Initiative Conference, April 24, 2017
Foreign Investment Reviews and the New Administration, U.S.-China Business Council, March 23, 2017
"Foreign Investment in the U.S.: Obtaining CFIUS Approval," J.P. Morgan Special Situations Investor Forum, March 13, 2017
"A Contractor's Guide to Doing Business with the Department of Homeland Security," Federal Publications Seminars, November 9, 2016
"The U.S. Contractor's Guide to Doing Business in Israel," Federal Publications Seminars, July 27, 2016

Recent Insights

News Articles

In November 2024, Wilson Sonsini’s Jeff Bank, Jamillia Ferris, and Stephen Heifetz were named among Washingtonian magazine’s 2024 “Top Lawyers,” a biennial directory of Washington’s top legal talent in various practice specialties, as researched by the editors and voted by peers.

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Client Highlights

On December 2, 2024, 9fin, the AI-powered analytics platform for debt capital markets, announced it has raised $50 million in a Series B round led by Highland Europe, with participation from existing investors Spark Capital, Redalpine, Seedcamp, 500 Startups, and Ilavska Vuillermoz Capital. The new funding will enable 9fin to invest further in its market-leading AI technology, grow its analytics team, and accelerate its expansion in the U.S.

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Recent Events

WSGR Events

Join Wilson Sonsini for a webinar on Tuesday, September 24, 2024 from 10:00 a.m. to 11:00 a.m. PT, where our esteemed panel will consider how federal enforcement priorities may differ between a Trump and Harris administration, and the likelihood of Biden administration enforcement policies continuing in either administration.

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Speaking Engagements

Wilson Sonsini is proud to partner with Helsinki Geoeconomics Week, organized by the Geoeconomics Society. The conference is a week-long international event exploring the intersection of economics and global power dynamics, focusing on the emerging profession of geoeconomists. Helsinki Geoeconomics Week is attended by professionals, academics, policymakers, business leaders, corporate strategists, investment analysts, and legal experts; focused on bridging the gap between theory and practice in geoeconomics, fostering interdisciplinary collaboration and shaping the future of the field through discussions, panels, and networking opportunities. Learn more about the event's origin and organizers here.

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