11th National Conference on CFIUS - DS by C5Group

11th National Conference on

April 24–25, 2025 | The Madison Hotel, Washington, DC

In-Person and Livestream Options Available

The Country’s Flagship Conference on New, Expanded Scope and Scrutiny of Foreign Direct Investments

Join Government Officials, In-House Executives and Outside Counsel for New, Critical Discussions on:

CHEVRON-RIGHT Post-U.S. Election: Practitioner and Former Government Perspectives on CFIUS Penalties and Enforcement

CHEVRON-RIGHT In-House Executive Insights: Behind the Scenes of Implementing a Mitigation Agreement

CHEVRON-RIGHT The Present and Future of Outbound Investment Policy

CHEVRON-RIGHT AI, ML, Quantum Computing and Connected Vehicles: How Emerging Tech Fits into the CFIUS Landscape

CHEVRON-RIGHT U.S. Steel Case Study: Is the Scope of National Security and Economic Security Expanding?

CHEVRON-RIGHT Safeguarding Data Centers, Personal Sensitive Data and the Tech Supply Chain

New Strategy Sessions on High Stakes, Time Sensitive Decisions:

Caret-right The Biggest “What Ifs” Affecting the Fate of Short, Medium and Long-Term Transactions

Caret-right Rethinking Key Decisions for Non-Notified Transactions and Mitigation Complexities

2025 SPEAKER FACULTY

GOVERNMENT SPEAKERS

Irmie “Ike” Blanton

Deputy Director, Economic Security, Office of Global Investment and Economic Security

U.S. Department of Defense

Elizabeth Cannon

Executive Director, Office of Information and Communications Technology and Services (OICTS), Bureau of Industry and Security

U.S. Department of Commerce

Dan Burke Director, Foreign Investment Risk Review

U.S. Department of the Air Force

Nicholas Jackson Chief, Foreign Investment Unit Federal Bureau of Investigation (FBI)

Eric S. Johnson

Principal Deputy Chief of the Foreign Investment Review Section, National Security Division

U.S. Department of Justice

Geoffrey Irving Director, Technology Division, OICTS

U.S. Department of Commerce

Jamieson McKay Director General, Foreign Investment Review and Economic Security Branch (FIRES) Innovation Science and Economic Development Canada, Government of Canada

Charles Morrison Policy Director House Select Strategic Competition Between the United States and the Chinese Communist Party Committee

Jennifer Danner Riccardi Senior Advisor Delegation of the European Union (Washington DC)

Brian Reissaus Senior Advisor, National Security Freshfields US LLP

Former Deputy Assistant Secretary for Investment Security

Operations, U.S. Department of Treasury

Timothy Varley

Deputy Director, DON Foreign Investment Review, Research, Development, and Acquisition (RD&A) U.S. Department of the Navy

Widad E. Whitman Economic Security and Global Investments Program Manager, Office of Manufacturing and Energy Supply Chains (MESC)

U.S. Department of Energy

DISTINGUISHED FACULTY

Scott Boylan Partner StoneTurn

Ryan Brady Partner White & Case LLP

Charles L. Capito Partner Morrison Foerster LLP

John P. Carlin Partner

Paul Weiss Rifkind Wharton & Garrison LLP

Randall Cook Managing Director Alvarez & Marsal

Shawn B. Cooley Counsel Weil, Gotshal & Manges LLP

Sarah Bauerle Danzman Resident Senior Fellow, Economic Statecraft Initiative Geoeconomic Center

Atlantic Council

Zachary N. Eddington Counsel Latham & Watkins LLP

MaryJean Fell Vice President, Legal T-Mobile

Nancy A. Fischer Partner

Pillsbury Winthrop Shaw Pittman LLP

Anne Salladin Partner Hogan Lovells US LLP Former Senior Counsel U.S. Department of the Treasury

Nathan D. Fisher Managing Director StoneTurn Former Unit Chief, Directorate of Intelligence, Federal Bureau of Investigation (FBI)

Jerry Fowler Director, CFIUS and National Security Control Risks

Robert A. Friedman Partner Holland & Knight LLP

Geoffrey M. Goodale Partner Duane Morris LLP

Zack Hadzismajlovic Partner, Head of Global Trade Group McCarter & English LLP

Steven Klemencic Managing Director Berkeley Research Group (BRG)

Michael Knipple CISO Summit BHC

Alexandra Lopez-Casero Partner Nixon Peabody LLP

Neil H. MacBride Partner Davis Polk & Wardell LLP Former General Counsel U.S. Department of the Treasury

Mario Mancuso, P.C. Partner Kirkland & Ellis LLP

Paul D. Marquardt Partner, Financial Institutions Davis Polk & Wardell LLP

Janine N. Slade

Covington & Burling LLP Former Deputy Director, Foreign Investment Risk Management, U.S. Department of Homeland Security

Eric Matrejek Managing Director Berkeley Research Group (BRG)

Vincent Mekles Managing Director Alvarez & Marsal

Nathan Mitchell Counsel Paul Weiss Rifkind Wharton & Garrison LLP

Christopher B. Monahan Partner Faegre Drinker LLP

John C. Rood

and Chairman Momentus Space Former Under Secretary of Defense for Policy, U.S. Department of Defense

Jared Roscoe Partner, Deputy General Counsel SoftBank Group International

Paul Rosen Partner Latham & Watkins LLP Former Assistant Secretary, Investment Security, U.S. Department of Treasury

Pierce Scranton Deputy Head North America/ Managing Director Temasek

Ivan A. Schlager, P.C. Partner Kirkland & Ellis LLP

Evan Sills Counsel

Kabealo Law

Attorney Advisor U.S. Department of Justice

Malcolm (Mick) J. Tuesley Partner Simpson Thacher & Bartlett LLP

John J. Vecchione Senior Litigation Counsel New Civil Liberties Alliance

Christina Zanette Assistant General Counsel, Export Compliance Honeywell

Jeremy B. Zucker Partner Dechert LLP

PRE-CONFERENCE WORKSHOPS

Wednesday, April 23,

9:00 am–12:30 pm (Registration opens at 8:00 am)

A* Due to the hands-on nature of the workshops, they will only be available for in-person attendance.

2025

A Complete Primer on CFIUS: Your Guide to the Process, Timelines and Whether to File—or Not

Designed for professionals who are new to all things CFIUS or seeking a refresher, this introductory session will discuss when and when not to submit a CFIUS filing. Delegates will gain an understanding of the national security reasons for CFIUS filings, the scrutiny given to filings, as well as the timelines and possible roadblocks.

Topics will include:

Part One: CFIUS Process

• What are the guidelines for the CFIUS review process

• What should companies do before an NSA

• Clarifying the grey areas

• Navigating non-notified transactions

Part Two: Requirements for Filings, Compliance and Mitigation

• What you need to do for representations and statements

• Obligations with national security agreements

Speakers Include:

Zack Hadzismajlovic Partner, Head of Global Trade Group McCarter & English LLP

• What to do when you realize you submitted something with a wrong statement and how to submit corrections

• Getting the right forms and the right check lists for making a notice and a declaration

Part Three: Real-World Examples and FAQs

• The types of questions CFIUS is likely to ask, why it is asking, and why the question might be asked more than once

1:30–5:00 pm (Registration opens at 12:30 pm)

BYour Updated Guide to CFIUS Penalties and Enforcement: What It Now Takes to Mitigate the Risk of Liability, Transaction Delays and Denials

During this in-depth interactive session, delegates will unpack what has (and hasn't) triggered enforcement and penalties-and the comprehensive set of lessons learned. This session will also discuss the steps to consider prior to a CFIUS filing to minimize risks.

Part One: What Constitutes a Violation and Type of Misconduct:

How CFIUS has Assessed:

• Failing to file, timely filing, mandatory declaration

• Non-compliance with the mitigation agreement

• Misstatements, omissions and false certifications

Part Two: Penalties Under the Microscope

Speakers Include:

Geoffrey M. Goodale Partner Duane Morris LLP Evan Sills Counsel Kabealo Law

Former Attorney Advisor U.S. Department of Justice

• Next steps upon receiving a notice of a penalty, including a written explanation of the misconduct

• Petitioning for reconsideration, including any defense, justification, mitigating factors, or explanation

• Calculating the penalty amount

Part Three: Aggravating and mitigating factors

• Analyzing the threat to national security

• Calculating how the conduct impaired or threatened to impair U.S. national security

• Determining whether the conduct was the result of negligence, intentional action, or willfulness

• Examining how often or persistent the conduct occurred, when was it realized, and what action was taken to correct it

DAY ONE

Thursday,

April 24, 2025

8:00 Registration and Breakfast

8:30 Opening Remarks from the Co-Chairs

Brian Reissaus

Senior Advisor, National Security Freshfields US LLP

Former Deputy Assistant Secretary for Investment Security Operations, U.S. Department of Treasury

Anne Salladin Partner

Hogan Lovells US LLP

Former Senior Counsel, U.S. Department of the Treasury

Janine N. Slade Special Counsel

Covington & Burling LLP

Former Deputy Director, Foreign Investment Risk Management, Department of Homeland Security

8:45

Interview: Penalties & Enforcement Actions

For the first time, the U.S. Department of the Treasury publicly named a company subject to a penalty. This is coupled with an increase in the number of companies under the enforcement microscope, and the rise in penalty amounts.

• Rationale behind publicizing the subject of a recent enforcement action

• Status report on the number of enforcement actions, types of enforcement and trends

• Is enforcement acting as a deterrent?

• How are penalties now being calculated?

• How are non-notified transactions being identified?

• What changes are expected and have recently occurred in the Treasury Department?

This session will analyze the current and anticipated impact of a new Administration, as well as the enduring aftermath of the CFIUS Annual Report to Congress. Topics will include trends and new, evolving expectations:

• Breakdown of trends and their hidden lessons

• How has the change been implemented

• Examining the increase in non-notified transactions and how much time has passed between the deal and the notice

• Are CFIUS reviews becoming a more “adversarial” process?

N. Eddington

IN-HOUSE EXECUTIVE PANEL

10:30 Behind the Scenes of Implementing a Mitigation Agreement

• What is it like to run a large transaction and subsequent mitigation

• How to break down silos

• How companies account for the costs of mitigation and to what extent the parties and CFIUS accounted for this at the review stage

• Deciding whether or not to address the operations side when negotiating a mitigation agreement

• Meeting privacy obligations for personal information of U.S. citizens

• Managing Cyber Security and Insider Threats at the operational level

• Implementing policies and processes formation, and standard operating procedures for oversight, auditing and monitoring of both systems and teams

MaryJean Fell Vice President, Legal T-Mobile

Scott Boylan Partner

StoneTurn

Michael Knipple CISO

11:15 U.S. Steel Case Study: Is the Scope of National Security and Economic Security Expanding?

CFIUS continues to review the controversial deal between U.S. Steel and Japanese-owned Nippon Steel. This raises questions of CFIUS’ jurisdiction, and what is now considered a national security concern.

• Delineating what is and what is not covered under the scope of CFIUS and how the scope has evolved

• How CFIUS should and should not be used, and the evolution of CFIUS usage: Is the committee being used for political purposes?

• Exploring the national security concern versus the economic security concern and the U.S. Industrial Base

• Determining the effect on allied countries

12:15 Networking Luncheon

Summit BHC Sponsored by

Ivan A. Schlager, P.C. Partner

Kirkland & Ellis LLP

Nancy A. Fischer Partner

Pillsbury Winthrop Shaw Pittman LLP

1:30 Unpacking the America First Investment Policy and Emerging Trends in CFIUS

The Trump administration issued a National Security Presidential Memorandum (NSPM) titled the “America First Investment Policy” in March 2025, with an aim to promote foreign investment while protecting domestic security interests. This session will look at how investment policy guidance is advancing under the new administration.

• Examining the roots of the NSPM and anticipating incoming initiatives

• Exploring the administration’s focus and the new direction for CFIUS practitioners

• Examining restrictions on U.S.-China and disincentivizing U.S. investment in China

• Tighter CFIUS reviews of inbound investment and a look at outbound investment strategy

• Implementing an expedited “fast-track” investment process

• Expediting environmental reviews

• Moving away from open-ended mitigation agreements

Neil H. MacBride Partner

Davis Polk & Wardell LLP

Former General Counsel

U.S. Department of the Treasury

Paul Rosen Partner

Latham & Watkins LLP

DAY ONE | Thursday, April 24, 2025

2:45 High Stakes, Sensitive Decisions on the Fate of Non-Notified Transactions: How Practitioners Are Now Advising on Whether or Not to File, and the New Mitigation Complexities

This session will delve into why and how transactions are becoming more complex, and how to best determine whether a CFIUS filing is necessary and weigh the risks of not filing.

• Deciphering the risk factors involved with not filing

• Determining whether a full filing is mandatory

• Assessing whether to file a declaration or a notice

• Calculating whether a voluntary filing will be more cost effective in the long run

• Anticipating which transactions do not warrant heightened scrutiny, including sectors and jurisdictions

• Is it possible to proactively structure a deal so as not to trigger a filing—and, if so, how?

• What matters to foreign investors in the current economic and geopolitical climate

3:30 Networking Break

John C. Rood

CEO and Chairman

Momentus Space

Former Under Secretary of Defense for Policy, U.S. Department of Defense

Robert A. Friedman

Partner

Holland & Knight LLP

Vincent Mekles

Managing Director

Alvarez & Marsal

3:45 Part One: Supply Chain Resilience and Critical Infrastructure

Part 1 of this two-part series will focus on CFIUS expectations for safeguarding infrastructure, including critical infrastructure, manufacturing, and processing capacity and the availability of critical goods, materials, and services.

• Assessing the vulnerability of U.S. ports, and infrastructure touching the gird, such as nuclear power, oil and gas works, solar power, wind farms, batteries and other renewable technology

• Keeping up-to-date on how our critical material supply chain is impacted by national security considerations

• Assessing the key infrastructure projects to protect

• How is CFIUS thinking about critical minerals

The U.S. Department of the Treasury issued final regulations (the Final Rule) this past fall, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the Outbound Order). The Final Rule provides the operative regulations and explanatory discussion regarding their intent and application. The regulations are in effect as of January 2, 2025.

• Examining how the Outbound Investment Program is working in real life

• Identifying the scope of the OIP and how it is different from the Executive Order

• How will U.S. persons outside of the US be treated, including those who are working for non-U.S. companies

• What policies and procedures can companies put in place

• How transactions are being reviewed

• Investing in prohibited areas, AI and quantum

• Raising or borrowing capital when you want to make overseas investments

• What are the guidance, qualifications and criteria for approvals?

Nicholas Jackson

Chief, Foreign Investment Unit Federal Bureau of Investigation (FBI)

Widad E. Whitman

Economic Security and Global Investments Program Manager, Office of Manufacturing and Energy Supply Chains (MESC) U.S. Department of Energy

Steven Klemencic

Managing Director

Berkeley Research Group (BRG)

Sarah Bauerle Danzman

Resident Senior Fellow, Economic Statecraft Initiative Geoeconomic Center Atlantic Council

Chrisopher B. Monahan

Partner

Faegre Drinker LLP

Charles Morrison

Policy Director

House Select Strategic Competition

Between the United States and the Chinese Communist Party Committee

5:15 Closing Remarks from the Conference Co-Chair and End of Day One Networking Cocktail Reception

GLOBAL FDI REGIMES

10:15 How International Regimes Are Now Defining “National Security” and “Economic Interest”

This session will explore what constitutes “national security” from global perspectives, and how enforcement is being approached in key jurisdictions.

• Examining the definition of “national security”

• Challenges with doing the analysis and coming up with a result

EUROPEAN UNION: Open Strategic Autonomy

• Trade outside the EU as an exclusive responsibility of the EU and not its Member States

• Open Strategic Autonomy

CANADA: Investment Canada Act (2024)

• Foreign investments in the critical minerals sector as a national security concern

• Determining whether an investment is of "net benefit", such as the effect on economics

FRANCE: Strategic sectors covered by the foreign investment control

• Agricultural products as far as they contribute to national food security objectives

Jamieson McKay

Director General, Foreign Investment Review and Economic Security Branch (FIRES) Innovation Science and Economic Development Canada, Government of Canada

Jennifer Danner Riccardi

Senior Advisor

Delegation of the European Union (Washington DC)

• Editing, printing, distribution of political and general information through print and online press services

GERMANY: Foreign Trade and Payments Act

• Safeguarding economic sectors and critical infrastructure

• Mandatory filing obligations for voting rights threshold

NETHERLANDS: National Security Screening Act (2023)

• Defining "national security", including niche markets such as semiconductors, quantum technology, and photonics

PART TWO: SUPPLY CHAIN RESILIENCE

11:15 AI, ML, Quantum Computing and Connected Vehicles: How Emerging Tech Fits into the CFIUS Landscape

Part 2 of this series will focus on safeguarding against digital risks, including cybersecurity.

• Examining the national security concerns with emerging tech

• What is in the draft regulations and how is the national security risk changing? How will this sector be regulated?

• How is CFIUS thinking about this sector, including the definition of “foundational technology”

• How do you classify tech as dual-use? The interplay of ITCS and CFIUS

• When you do and don’t need to file

Mario Mancuso, P.C. Partner

Kirkland & Ellis LLP

Eric Matrejek Managing Director Berkeley Research Group (BRG)

Geoffrey Irving

Director, Technology Division, OICTS

U.S. Department of Commerce Great energy, in person, excellent panel speaks, good topics, nice representation from recent former and current government officials.

STRATEGY SESSION #2

12:00 High Stakes, Time

Sensitive Decisions: The Biggest “What Ifs” Affecting the Fate of Short, Medium and Long-Term Transactions

• Developing your mitigation negotiation strategy early in the transaction process

• Calculating when to involve third-party monitors and choosing the right service provider

• Determining what is considered “limited risk”

• Structuring a deal when there is urgency and what to do if the transaction closes before the CFIUS review

• Working within the CFIUS system while continuing to do business

• Mitigating lower-probability risk agreements

• Mitigating hypothetical future scenarios at the beginning of the agreement – anticipating CFIUS’ long-term risk considerations

• Drafting an agreement for your client with the highest-risk possibilities in mind

12:30 Networking Luncheon

Jared Roscoe

Partner, Deputy General Counsel SoftBank Group International

Nathan Mitchell Counsel

Paul Weiss Rifkind Wharton & Garrison LLP

Ryan Brady Partner White & Case LLP

1:45 SPOTLIGHT on Private Equity and Venture Capital Investment Fund Structures That Could Trigger (and Survive) a CFIUS Review

This session will look at investment fund structures, including what does and doesn’t fall under the Code of Federal Regulations (CFR) Section 800-307

• The role and responsibility of the PE Manager, and when to notify of foreign investments

• Structuring your investment fund

• Determining what is, and is not considered a covered investment

• When a fund structure or investment is at risk of becoming the subject of heightened scrutiny

• Calculating your risk and potential exposure-and the bigger picture impact on the transaction

Pierce Scranton Deputy Head North America/ Managing Director Temasek

Charles L. Capito Partner

Morrison Foerster LLP

Moderator:

Paul D. Marquardt Partner, Financial Institutions Davis Polk & Wardell LLP

2:30 Real Estate Transactions, the Increased National Security Concern and Scope of CFIUS Coverage

This session will dissect key developments, including the U.S. Department of the Treasury’s Notice of Proposed Rule Making to Expand CFIUS Coverage of Real Estate Transactions Near Military Installations, issued July 2024. This proposed rule would add over 50 military installations, across 30 states, to CFIUS' existing jurisdiction.

We will also look at the presidential order prohibiting the purchase of certain real estate operating as a cryptocurrency mining facility located within one mile of Francis E. Warren Air Force Base (F.E. Warren AFB), as well as the removal of equipment owned by MineOne Partners Limited.

3:15 Networking Break

Irmie “Ike” Blanton Deputy

Director,

Economic Security, Office of Global Investment and Economic Security U.S. Department of Defense

Dan Burke Director, Foreign Investment Risk Review

U.S. Department of the Air Force

Timothy Varley

Deputy Director, DON Foreign Investment Review, Research, Development, and Acquisition (RD&A)

U.S. Department of the Navy

Sponsored by

3:30

TikTok Action, Chevron and More Cases: Is This the Start of More CFIUS Litigation?

Ralls Corp. v. Comm. on Foreign Inv. in the United States (2014) A review of the only litigation case in the CFIUS sector.

TikTok

This session will give an update on the litigation involving TikTok, and parent company ByteDance, as well as a look at the Protecting Americans from Foreign Adversary Controlled Applications Act (2024) passed by Congress.

Chevron Decision and the Aftermath

• Examining due process rights

• Debating whether there is a cause for litigation and if CFIUS is acting beyond its scope

• Determining what (if any) recourse a purchasing company has against the seller, when facing a CFIUS penalty

• Predicting the consequences of taking legal action and the best/worst case outcome

CFIUS AND EXPORT CONTROLS

John J. Vecchione

Senior Litigation Counsel

New Civil Liberties Alliance

4:15 Export Control Classification: The Evolving Scope of Critical Technology and How it Affects Mandatory Filings

This session will delve into the Export Control Reform Act of 2018 (ECRA) and the EAR99 for low-technology consumer goods, and its interplay with FIRRMA and how presidential authority to regulate and enforce export controls is now being implemented.

• Classifying technology under EAR99, when you need a licence and where the tech can be exported to

• Determining when BUS will make a unilateral technology classifications, and which agencies will get involved

• Practical impact of expanding the mandatory declaration process

• Unpacking the evolving interplay of export controls and foreign investment reviews

• Evaluating whether or not your company has critical technology

• Discussing how presidential authority is being coordinated with the Secretaries of Commerce

• Defense, Energy and State to identify “emerging and foundational technologies” that are essential to national security, but are not deemed “critical technologies” subject to CFIUS review

• Emerging implications for exporters operating in sectors that are identified as involving foundational or emerging technologies

Alexandra Lopez-Casero Partner Nixon Peabody LLP

Christina Zanette

Assistant General Counsel, Export Compliance Honeywell

Moderator: Jerry Fowler

Director, CFIUS and National Security Control Risks

5:00 Closing Remarks from the Conference Co-Chairs and Conference Concludes

UPCOMING EVENTS

hands-helping Global Sponsorship Opportunities

With conferences in the United States, Canada, Latin America and Europe, the C5 Group of Companies: American Conference Institute, the Canadian Institute, and C5 Group, provides a diverse portfolio of conferences, events and roundtables devoted to providing business intelligence to senior decision makers responding to challenges around the world.

Don’t miss the opportunity to maximize participation or showcase your organization’s services and talent. For more information please contact us at: SponsorInfo@AmericanConference.com

Founded in 1983, Alvarez & Marsal is a leading global professional services firm. Renowned for its leadership, action and results, Alvarez & Marsal provides advisory, business performance improvement and turnaround management services, delivering practical solutions to address clients' unique challenges. With a world-wide network of experienced operators, world-class consultants, former regulators and industry authorities, Alvarez & Marsal helps corporates, boards, private equity firms, law firms and government agencies drive transformation, mitigate risk and unlock value at every stage of growth.

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Supporting Sponsors Associate Sponsor

With a global platform of approximately 4,000 lawyers in 21 cities across the United States, Europe, the Middle East and Asia, Kirkland & Ellis provides elite legal advice and a relentless commitment to client service. Kirkland is a market-leader in each of its core practice areas including private equity, M&A and other complex corporate transactions; investment fund formation and alternative asset management; restructurings; high-stakes commercial and intellectual property litigation; and government, regulatory and internal investigations. To learn more, please visit www.kirkland.com.

Paul, Weiss, Rifkind, Wharton & Garrison LLP is a premier firm of more than 1,000 lawyers with diverse backgrounds, personalities, ideas and interests who provide innovative and effective solutions to our clients’ most complex legal and business challenges. The firm represents many of the world’s largest and most important public and private corporations, asset managers and financial institutions, as well as clients in need of pro bono assistance.

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