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 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.

• Export Controls and Defense Technology Transfers
  • 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 start-up.
  • Advised European defense manufacturer on obtaining a multi-party 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 & National Security (CFIUS and FOCI-mitigation)
  • 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, unblocking 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.

• 22V Research, Webinar on Russian Sanctions and the Conflict in Ukraine, March 8, 2022
• 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
  • 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
  • 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
  • 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