Sullivan & Cromwell’s National Security Practice draws on the expertise of a wide range of former high-level government officials with deep national security experience to offer clients holistic advice on navigating the challenges at the growing nexus between business and national security interests, including supply chain issues. Our practice includes former senior officials and attorneys from the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN), the Federal Reserve, the Department of Homeland Security, the Department of State, the Department of Justice and the national security units of multiple U.S. Attorneys’ offices.
Our team includes former government lawyers who advised on strategic and policy-level issues involving national security.
- Adam Szubin, former Acting Treasury Department Under Secretary for Terrorism and Financial Intelligence and Director of OFAC
- Andrew DeFilippis, a former senior member of the National Security and International Narcotics Unit in the U.S. Attorney’s Office for the Southern District of New York and Counselor to the Secretary of Homeland Security
- Michael George DeSombre, former United States Ambassador to the Kingdom of Thailand
- Nicole Friedlander, former Chief of the Complex Frauds and Cybercrime Unit in the U.S. Attorney’s Office for the Southern District of New York
- Amanda Houle, former Co-Chief of the National Security & International Narcotics Unit in the U.S. Attorney’s Office for the Southern District of New York
- Sharon Cohen Levin, former head of the Money Laundering and Asset Forfeiture Unit in the U.S. Attorney’s Office for the Southern District of New York
- Anthony Lewis, former Deputy Chief of the Terrorism and Export Crimes Section in the U.S. Attorney’s Office for the Central District of California
Our lawyers, including several with active security clearances and others who can reactivate their clearances on short notice, help clients around the world anticipate and respond to the rapidly changing geopolitical environment and rules addressing national and international security concerns. We are known for our work involving economic sanctions, white-collar defense, anti-money laundering, counterterrorism, cybersecurity, export controls, import restrictions (such as the Uyghur Forced Labor Protection Act), the Foreign Corrupt Practices Act (FCPA), cryptocurrency, artificial intelligence and the defense sector. In addition to traditional enforcement matters, we also advise on compliance matters and national and international security issues that arise in M&A deals and other corporate transactions, including the Committee on Foreign Investment in the United States (CFIUS) and non-U.S. Foreign Direct Investment (FDI) reviews.
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.
Our multidisciplinary approach allows lawyers to collaborate across practices—including our market-leading teams in Financial Services, Criminal Defense & Investigations, Project Development & Finance, Foreign Investment and Trade Regulations, and M&A—to give clients the most informed and sophisticated advice. A number of our partners have extensive experience representing clients in negotiations with governments in Latin American, African and Middle Eastern countries and, when necessary, arbitrating foreign investment protection disputes.