Sullivan & Cromwell LLP Logo
  • Home
  • Lawyers
  • Practices
  • Insights
  • About
  • Careers
  • Alumni
  • Twitter icon
  • LinkedIn icon
  •  icon
  • Podcasts icon
© 2025 Sullivan & Cromwell LLP
    • Home
    • Lawyers
    • Practices
    • Insights
    • About
    • Careers
    • Alumni
    Home /  Practices /  Foreign Investments and Trade Regulations

    Foreign Investments and Trade Regulations

    Related Lawyers

    Sullivan & Cromwell is one of the leading legal advisers in matters related to U.S. international trade and investment, including supply chain issues, backed by years of experience and a record of client success.

    The Firm advises U.S.-based clients making or receiving non-U.S. investments and works closely with U.S. and non-U.S. companies and financial institutions with their international activities. S&C advises on issues involving compliance with anti-money-laundering laws, including: the U.S. Bank Secrecy Act and the USA Patriot Act; compliance with U.S. economic sanctions administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the U.S. State Department, the U.S. Foreign Corrupt Practices Act (FCPA); and other international trade and investment laws in the context of transactions.

    We routinely advise multinational companies on their expanding obligations to protect and conduct due diligence on their global supply chains to ensure compliance with various laws and regulations, including tariffs, import controls and customs laws; the European Union’s Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD); and forced labor laws and restrictions, including the Uyghur Forced Labor Prevention Act.

    S&C lawyers also advise on establishing and upgrading structures, procedures and compliance programs in order to avoid violations. In addition, from the Defense Production Act of 1950, to the creation of the Committee on Foreign Investment in the United States (CFIUS) in 1975, to the Exon-Florio amendment in 1988 and the Foreign Investment and National Security Act of 2007, S&C has been advising clients on federal rules regarding the national security review of foreign investment and structuring acquisitions and other investments in order to obtain the necessary regulatory approvals.

    S&C’s highly regarded and world-renowned Criminal Defense and Investigations Group and National Security Practice regularly handle matters involving international trade issues, including the defense of organizations and officers of companies facing investigations or charges under the FCPA, U.S. economic sanctions, import and export controls and anti-money-laundering laws. The Firm’s criminal defense and national security teams include former federal and state prosecutors; former senior officials and attorneys from the Treasury Department, the Office of Foreign Assets Control, the Financial Crimes Enforcement Network (FinCEN), the Department of Homeland Security, and the Department of State; former bank regulatory enforcement counsel; and the leading practitioners in banking and securities regulation. These lawyers also have extensive federal and state court trial experience.

    S&C’s extensive experience with foreign investment and trade issues—coupled with the Firm’s expertise in finance and investment—are key factors in clients’ success.

    Read More

    Spotlight

    Chambers USA Ranks S&C Highly for 2025

    Read More
    blue-award-trophies

    Sharon Cohen Levin and Andrew DeFilippis Discuss Tariff Evasion and Supply Chain Management in NYU Law’s Compliance & Enforcement Blog

    Read More
    cohen-levin-_defilippis_800x400_72dpi

    Thomas White and Andrew DeFilippis Author Bloomberg Law Article on Risks and Opportunities in New Tariff Environment

    Read More

    S&C Tariffs Tracker

    Read More
    tariffs-tracker_824x357

    Key Takeaways for U.S. Companies Considering Cross-Border Investments

    Read More
    sc_ci_template_368x159
    • Experience
    • Rankings and Recognitions
    • News
    • Publications, Videos and Podcasts
    • Practice Contacts
    • Related Practices
    • Related Lawyers
    Experience

    Experience

    Selected Experience Related to U.S. Economic Sanctions and Anti-Money-Laundering Issues 

    • TD Bank, in connection with an investigation of TD Bank’s anti-money-laundering controls and compliance with the Bank Secrecy Act by the Office of the Comptroller of the Currency (OCC) and Financial Crimes Enforcement Network and with the SEC for related violations of sections 17(a)(2) and (3) of the Securities Act of 1933.
    • HSBC Group, in connection with criminal and regulatory investigations of its historical Office of Foreign Assets Control (OFAC) sanctions and anti-money-laundering compliance programs.
    • Citibank, regarding issues relating to a consent order issued by the OCC regarding anti-money-laundering and U.S. economic sanctions compliance.

    • Standard Chartered Bank, in deferred prosecution agreements with the Department of Justice and the Manhattan District Attorney’s Office and regulatory settlements with the New York State Department of Financial Services, the Federal Reserve and OFAC, all related to OFAC sanctions and anti-money-laundering compliance.
    • various financial institutions and other clients, in connection with economic sanctions compliance and anti-money-laundering in the context of various international trade and investment matters, such as bank loans, securities underwritings and offerings; the conduct of banking operations; and in the context of mergers and acquisitions, joint ventures and other investment activities.

    Selected Experience in Foreign Corrupt Practices Act Investigations 

    • a major European oil company, in investigations by the Department of Justice, Securities and Exchange Commission and U.K. Serious Fraud Office into alleged violations of the FCPA and U.K. Bribery Act arising from the company’s joint ventures on multiple continents.
    • one of the world’s largest multinational automotive manufacturing companies, in a review by U.S. and U.K. regulators of the company’s automobile and parts supply chains into various markets, including Russia, Belarus, Poland, Finland, Japan, Ukraine and China.
    • a U.S. subsidiary of a foreign company that provides aviation services and aftermarket support to commercial, general and government aircraft operators, in a DOJ investigation into alleged FCPA violations. The DOJ is primarily focused on the U.S. subsidiary’s business activities in Latin America. 
    • a major engineering and electronics conglomerate, in entering into a settlement with the U.S. Securities and Exchange Commission to resolve FCPA charges relating to conduct by a former employee. The SEC did not impose a civil money penalty and did not bring charges based on the anti-bribery provision of the FCPA.
    • a major international energy company, in multiple investigations into alleged violations of the FCPA in North Africa, the Middle East and Central Asia.
    • a U.S. subsidiary of a Japanese company, in connection with FCPA compliance and with internal investigations of allegations of FCPA violations.

    Selected Experience Involving Other Foreign Investment Issues and Regulatory Agencies

    • Barclays, ING Group, HSBC Group and Standard Chartered Bank, in the successful resolutions of multiagency criminal and regulatory investigations relating to their compliance and economic sanctions and/or anti-money-laundering regulations.
    • Koninklijke Philips Electronics, in entering into a settlement with the U.S. Securities and Exchange Commission to resolve Foreign Corrupt Practices Act charges relating to conduct by former employees of a Polish subsidiary of Philips.

    Selected Experience Involving Matters Related to Committee on Foreign Investment in the United States (CFIUS) Review of Foreign Investment Transactions

    • Buyers and sellers in various industries, in connection with CFIUS reviews of foreign investment, including companies in the financial institutions sector, the semiconductor and semiconductor fabrication sectors, the power generation sector, the energy exploration sector and the transportation sector, some of the most sensitive sectors for the purposes of national security reviews.
    • Cymer, on CFIUS matters related to its merger with ASML Holding pursuant to which ASML acquired all of the outstanding common stock of Cymer in a transaction valued at approximately $3.9 billion.
    Read More
    Rankings and Recognitions

    Rankings and Recognitions

    • Chambers USA Ranks S&C Highly for 2025

      June 6, 2025
    • Chambers USA Ranks S&C Highly for 2024

      June 6, 2024
    • Chambers USA Ranks S&C Highly for 2023

      June 2, 2023
    Read More
    News

    News

    • S&C Advises AXA in Exclusive Negotiation to Sell AXA Investment Managers to BNP Paribas for €5.4 Billion

      August 1, 2024
    • Sharon Cohen Levin and Amanda Houle Discuss BIS’s Voluntary Self-Disclosure Policies in NYU Law’s Compliance & Enforcement Blog

      February 9, 2024
    • S&C Advises DISH Network in Merger Agreement with EchoStar

      August 24, 2023
    • S&C Advises Seagen in $43 Billion Acquisition by Pfizer

      March 15, 2023
    • Jay Clayton Discusses U.S.-China Relations on CNBC’s “Squawk Box”

      December 7, 2022
    • Jay Clayton Comments on United States-China Trade Relations on CNBC’s “Squawk Box”

      November 1, 2022
    Read More
    Read More
    Publications, Videos and Podcasts

    Publications, Videos and Podcasts

    • DOJ Resumes FCPA Enforcement

      S&C Memos |  June 11, 2025
    • Sharon Cohen Levin and Andrew DeFilippis Discuss Tariff Evasion and Supply Chain Management in NYU Law’s Compliance & Enforcement Blog

      Articles |  June 4, 2025
    • Two Federal Courts Strike Down Recent Tariffs

      S&C Memos |  June 2, 2025
    • EU and UK Expand Sanctions Against Russia

      S&C Alerts |  May 21, 2025
    • EU Court Landmark Ruling Reinforces Transparency of EU Institutions

      S&C Memos |  May 15, 2025
    • President Trump Issues Executive Order, ‘Fighting Overcriminalization in Federal Regulations’

      S&C Memos |  May 14, 2025
    Read More
    Read More
    Practice Contacts

    Practice Contacts

    Eric J. Kadel Jr. Headshot Photo
    Eric J. Kadel Jr.
    Washington, D.C.
    +1-202-956-7500
    Email
    vCard
    Christopher L. Mann Headshot Photo
    Christopher L. Mann
    New York
    +1-212-558-4625
    Email
    vCard
    Read More
    Related Practices

    Related Practices

    • Capital Markets
    • Corporate Governance
    • Credit & Leveraged Finance
    • Criminal Defense & Investigations
    • Environmental Transactions
    • Environmental, Social and Governance (ESG)
    • Executive Compensation
    • Financial Services
    • General Practice
    • Intellectual Property & Technology Transactions
    • Mergers & Acquisitions
    • Project Development & Finance
    • Real Estate
    • Restructuring and Special Situations
    Sullivan & Cromwell LLP Logo
    • Twitter icon
    • LinkedIn icon
    • RSS Feed icon
    • Podcasts icon
    • Home
    • Contact Us
    • Information Policy Relating to Cookies
    • Privacy Policy
    • California Privacy Policy
    • Website Notice
    • Attorney Advertising Notice
    © 2025 Sullivan & Cromwell LLP