Christian Kozlowski

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

In his government contracts practice, Christian advises defense and civilian contractors on a range of issues, including compliance with Federal Acquisition Regulations (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS) requirements. Christian also advises companies on sales through the US General Services Administration’s Multiple Award Schedule (Federal Supply Schedule), including compliance questions related to pricing and contract modifications.

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.