Christian Kozlowski

His experience working with shifting laws and regulations in reaction to a shifting geopolitical outlook allows him to help clients traverse a complicated regulatory landscape.

Christian’s national security practice focuses on all stages of the foreign direct investment review process in the United States overseen by CFIUS. He advises clients at all stages of the business life cycle on how to most effectively engage with CFIUS on issues of US national security. Christian routinely appears before CFIUS on behalf of clients in both voluntary submissions and as part of the “non-notified inquiry” process.

He also works with clients to navigate foreign ownership, control, and influence (FOCI) issues as they may arise within the context of transactions involving businesses that holds a security clearance as overseen by the Department of Defense’s Defense Counterintelligence and Security Agency (DCSA) (formerly the Defense Security Service). Christian is a member of the Morgan Lewis CFIUS Working Group.

With regard to export controls and sanctions, Christian helps companies address the regulatory obligations imposed by the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), Foreign Corrupt Practices Act (FCPA), and National Industrial Security Program Operation Manual (NISPOM).

He counsels clients regarding compliance with international trade laws and regulations administered by the DCSA, Department of Commerce, Department of State, and Department of the Treasury’s Office of Foreign Asset Control (OFAC).

Christian works with clients to conduct internal investigations, scope possible violations, develop comprehensive strategies for responding to potential issues, prepare voluntary and directed disclosures, draft and update compliance policies and procedures, and conduct compliance training. Christian also advises clients on the registration and other obligations associated with the Foreign Agents Registration Act (FARA). He has experience conducting international trade compliance–related diligence in mergers, acquisitions, minority investments, and financing transactions.