Matthew R. Rabinowitz

Recognized by Chambers USA as a CFIUS Expert, Matthew also assists U.S. sellers and foreign buyers in obtaining clearances from the Committee on Foreign Investment in the United States (CFIUS), with a particular focus on China-related transactions. He is a trusted advisor to foreign investors and U.S. businesses of all sizes, offering novel solutions to help parties navigate the complexities of the CFIUS review process, from the initial structuring stages throughout the transaction life cycle.

• Represented a Norwegian semiconductor company in multiple U.S. acquisitions, securing expedited CFIUS approvals, advising on national security agreement compliance, and providing ongoing CFIUS monitoring.
• Represented a Korean state-owned nuclear and hydroelectric operator in its strategic investment in a U.S. nuclear reactor design company, including negotiation of transaction documents and CFIUS review.
• Advised a U.S.-based venture capital fund on regulatory compliance for AI and emerging technology investments, including CFIUS reviews, FOCI analysis, and export control due diligence.
• Advised U.S. pension funds on compliance with new outbound investment regulations, including due diligence on technology sector transactions and negotiation of contractual safeguards to mitigate regulatory risk.
• Represented a U.S. semiconductor company in a CFIUS filing and national security agreement negotiation for the sale of its chip and wafer fabrication business, involving complex national security issues and multiple re-filings.
• Represented an insurance marketing company in securing CFIUS clearance for an investment by a foreign corporation, including review of sensitive personal data collection and compliance issues.
• Advised a Chinese energy company on CFIUS jurisdiction and filing strategy for its proposed hostile acquisition of a controlling interest in a U.S. oil and gas assets owner.
• Successfully represented U.S. digital security and technology company in connection with sale of physical security business to French electronic equipment company.
• Successfully represented Chinese government-owned client in CFIUS review of acquisition of a global semiconductor equipment provider.
• Successfully obtained CFIUS clearance representing seller of power-management-integrated circuits for consumer electronics in connection with acquisition by Chinese-owned joint venture.
• Successfully obtained CFIUS clearance for Chinese-based consortium in connection with acquisition of a semiconductor company.
• Obtained CFIUS clearance for Korean and Japanese investors in various nuclear fusion technology companies.
• Represented numerous companies in responding to non-notified CFIUS inquiries.

• Economic Sanctions and Embargoes
  • Advised global energy company on global trade sanctions and export controls, guiding the company through complex regulatory challenges across multiple jurisdictions.
  • Advised Japanese semiconductor and technology companies on U.S. sanctions and export controls, including product classifications, licensing for exports to China, supply chain compliance, and training programs in Japanese.
  • Advised a global marine and energy technology company on sanctions and export control compliance, including evolving Russia, Iran, and China restrictions, oil price cap enforcement, and circumvention risks in the shipping sector.
  • Counseled aircraft manufacturers, aircraft lessors and airlines on compliance with Russia-related sanctions programs.
  • Advised foreign manufacturers on the complexities of doing business in Iran, including an analysis of secondary sanctions and state sanctions.
  • Assisted foreign bank with comprehensive, on-site internal review of sanctions compliance program.
• Export Controls and Sanctions
  • Advised leading space and satellite companies on global export controls, sanctions, anti-boycott, and anti-corruption compliance, including licensing and regulatory issues across U.S., UK, and EU regimes.
  • Assisted multiple Swiss financial institutions conduct comprehensive on-site review and evaluation of OFAC sanctions compliance program.
  • Advised leading Chinese technology companies on U.S. export control, trade policy, and compliance matters, including guidance on advanced computing restrictions, outbound investment rules, and sensitive data regulations.
  • Advised multiple companies seeking Hong Kong Exchange IPOs on U.S. export controls, sanctions, tariffs, and outbound investment rules, with a focus on semiconductor and automotive sector compliance risks.
  • 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 aviation industry stakeholders, including global OEMs, MROs, and an international trade group, on sanctions and export controls compliance, Section 232 aircraft investigations, and the impact of U.S. and E.U. trade policies on financing and commercial strategies.
  • Advised global aircraft parts suppliers and MRO service providers on ITAR and EAR compliance, sanctions, licensing, and defense service authorizations, including matters involving civil, military, and embargoed-country aircraft.
  • Served as a special international trade counsel on U.S. export matters in connection with $800 million IPO on the Hong Kong Stock Exchange by a Chinse electric vehicle manufacturer.
  • Drafted export compliance policy to assist U.S. and Canadian aerospace company with trade and security compliance.
  • Conducted a comprehensive review of life science company's export control compliance matters, including drafting policies and procedures, enhancing the company's export classification database and submitting a voluntary self-disclosure.
  • Advised major social networking technology company on export control and sanctions laws in connection with global satellite and UAV communications project.
• Foreign Corrupt Practices Act (FCPA)
  • Assisted a global manufacturer with conducting a comprehensive FCPA review of its policies, practices and procedures.
  • Reviewed and analyzed FCPA issues in connection with potential acquisition of U.S.-based medical optics company by a publicly traded Japanese corporation.

• Recognized by Chambers USA in International Trade: CFIUS Experts (Nationwide) (2022–2025)
• Recognized by The Legal 500 U.S. as a Next Generation Partner in International Trade: CIFUS (2024–2025) and as a Rising Star in International Trade (2019–2023)
• Speaking Engagements
  • “2022 Bank Counsel Seminar,” Western Bankers, November 14 – 15, 2022, Las Vegas, Nevada
  • “Screening for Supply Chain Risk,” Pillsbury CLE Marathon, September 22,2022. Tysons Corner, Va.
  • “Supply Chain Risks and the New Challenges of Doing Business Globally,” Pillsbury CLE Virtual Marathon, January 13, 2022.
  • “Select Bay Area: Investor Immersion Program,” GlobalSF Seminar, January 2020. San Francisco, Calif.
  • “CFIUS for Startups: Understanding Foreign Investment Restrictions,” Pillsbury CLE Marathon, January 2020. San Francisco and San Diego, Calif.
  • “Aviation Legal Panel: The Impact of a Changing Regulatory Landscape,” ACC Airline Conference 2019, November 2019. London, UK.
• Press and Media
  • Quoted in “Real Estate Takes on Heightened Focus Under Trump’s CFIUS,” Law360, March 12, 2025.
• Firm Publications

  • “Overview of the Proposed ‘Reverse CFIUS’ Process via the National Critical Capabilities Defense Act of 2022,” June 21, 2022. Coauthor.

  • “Further Sanctions Issued Against Russia: Services, Export Controls and Visa Restrictions,” May 17, 2022. Coauthor.

  • “BIS Hits Russia and Belarus with Sweeping New Export Control Restrictions,” March 3, 2022. Coauthor.

  • “Further EU and UK Measures Taken Against Russia,” February 22, 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.

  • “Commerce Imposes New Export Controls on Cybersecurity Items and Adds a Corresponding License Exception,” October 21, 2021. Coauthor.

  • “Biden Administration Updates Framework for China-Related Investment Prohibitions and Expands the Scope of Restricted Chinese Companies,” July 7, 2021. Coauthor.

  • “U.S. Announces Broad Array of New Russia Sanctions,” April 21, 2021. Coauthor.

  • “Commerce Department’s New ICTS Rule Raises Additional Considerations for Cross-Border Transactions,” January 20, 2021. Coauthor.

  • “U.S. Commerce Department Publishes Lists of Military End Users in China and Russia Subject to Export License Requirements,” December 23, 2020. Coauthor.

  • “China Tensions Persevere: Trump Issues Executive Order Prohibiting U.S. Investments in Chinese Companies,” November 15, 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 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.
  • “U.S. Commerce Department Imposes New Restrictions on Huawei,” August 18, 2020. Coauthor.
  • “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,” August 12, 2020. Coauthor.
  • “Executive Orders Target TikTok and WeChat Application Makers,” August 10, 2020. Coauthor.
  • “U.S. Government Efforts to Eliminate Supply Chain Threats from China to Telecommunications Networks,” June 5, 2020. Coauthor.
  • “U.S. Government Efforts to Eliminate Supply Chain Threats from China to Telecommunications Networks,” June 5, 2020. Coauthor.
  • “BIS Adds 33 Chinese Entities to Entity List,” May 23, 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, 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.
  • “Temporary FEMA Rule: Export Approvals Required for Certain Personal Protective Equipment,” April 10, 2020. Coauthor.
  • “Mitigating CFIUS Risks for Foreign Lenders and Investors as Defaults and Uncertainty Mount in the COVID-19 World,” April 3, 2020. Coauthor.
  • “CFIUS Update: Chinese Company Ordered to Divest Acquisition of U.S. Hotel Software Company,” March 10, 2020. Coauthor.
  • “CFIUS Unveils Proposed Rule to Impose Filing Fees,” March 9, 2020. Coauthor.
  • “U.S. Expands Secondary Sanctions to Iran’s Industrial Sectors,” January 17, 2020. Coauthor.
  • “Compliance in 2020 – Key Takeaways from the ITAR Cloud Rule,” January 16, 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.
  • “Commerce Department Publishes Interim Final Rule Controlling Geospatial Imagery Software for Training AI,” January 10, 2020. Coauthor.
  • “Commerce Department Issues New Proposed Rules on Telecommunications Supply Chain,” November 27, 2019. Coauthor.
  • “New Proposed CFIUS Regulations Implementing FIRRMA,” September 23, 2019. Coauthor.
  • “Update on U.S. Government Review of ‘Emerging and Foundational’ Technologies,” July 29, 2019. Coauthor.
  • “Huawei Remains on the BIS Entity List but Senior Officials Suggest Export Licenses May Be Considered,” July 16, 2019. Coauthor.
  • “U.S. Commerce Department Releases Proposed Rulemaking for Export Controls on Emerging Technologies,” November 20, 2018. Coauthor.
  • “U.S. State Department Adds New Hotels to Cuba Restricted List,” November 19, 2018. Coauthor.
  • “OFAC Announces Sanctions Against Saudi Arabian Government Officials Pursuant to Global Magnitsky Act,” November 15, 2018. Coauthor.
  • “Reinstatement of Iran Sanctions,” November 5, 2018. Coauthor.
  • “CFIUS Announces Pilot Program Requiring Mandatory Declarations for Certain Non-Controlling Investments in Specified Critical Technology Companies,” October 11, 2018. Coauthor.
  • “U.S. Formalizes Snap-Back of Sanctions with New Executive Order,” August 8, 2018. Coauthor.
  • “Congress Reaches Agreement on CFIUS Reform Legislation Broadening National Security Reviews and Addressing Emerging Technologies,” July 30, 2018. Coauthor.
  • “Differing CFIUS Reform Bills Move Through U.S. House and Senate,” June 26, 2018. Coauthor.
  • “New Proposed Trade Legislation Contains Additional Trade and Investment Restrictions Involving China,” May 18, 2018. Coauthor.
  • “United States Announces Withdrawal from JCPOA,” May 8, 2018. Coauthor.
  • “Trump Administration Considering Use of IEEPA To Restrict U.S. Technology Transfer to China,” April 12, 2018. Coauthor.
• External Publications
  • “Navigating the Current Sanctions Landscape in Venezuela,” WorldECR, May 1, 2019.
  • “Paying the Price: An Overview of Deceptive Sales Pricing,” ABA What’s In Store Newsletter, Winter 2015.