Tony Busch

Tony is a national security-focused international trade lawyer who advises companies how to contend with complex export controls, investment restrictions, and economic sanctions arising from an increasingly contentious global regulatory landscape.

Tony counsels clients on compliance with U.S. export controls, including the Export Administration Regulations, the International Traffic in Arms Regulations, and nuclear export controls. Tony also advises on foreign investment controls administered by the U.S. Department of the Treasury’s Office of Investment Security (OIS), including the Outbound Investment Security Program focused on semiconductors, quantum, and artificial intelligence, as well as inbound reviews conducted by the Committee on Foreign Investment in the United States (CFIUS). Tony’s experience is particularly strong in the areas of semiconductors and semiconductors manufacturing, data centers and artificial intelligence, software and encryption, aerospace and aviation, government contracting, and materials processing. Other matters Tony handles include Office of Foreign Assets Control (OFAC) economic sanctions matters, Antiboycott Regulations compliance, Foreign Trade Regulations filing procedures, and Bureau of Economic Analysis surveys.

In corporate deals, Tony identifies transactions that may trigger CFIUS Part 800 mandatory disclosure obligations, Defense Counterintelligence and Security Agency (DCSA) Foreign Ownership, Control, and Influence change condition reporting and/or mitigation requirements, and Directorate of Defense Trade Controls (DDTC) 60-day notice requirements.

Tony’s services also include interfacing on clients’ behalf with regulatory authorities such as the Bureau of Industry and Security, DDTC, CFIUS, DCSA, and Treasury’s OIS and OFAC in preparing sanctions delisting petitions, performing self-classification analysis, preparing license applications and classification requests, managing internal investigations and voluntary self-disclosures of past trade violations, drafting compliance policies, and performing international trade compliance due diligence for mergers, acquisitions, and other corporate transactions.

Tony began his practice in federal government contracting, investigations, and False Claims Act litigation and is thus particularly sensitive to the needs of clients doing business with the government or subject to government investigation. Prior to his legal career, Tony served as counterterrorism analyst.