Chase Kaniecki’s practice focuses on international trade and national security matters, including CFIUS and global foreign direct investment, economic sanctions, export controls, customs, and trade remedies.

He advises clients on international trade and national security issues and foreign direct investment matters, including filing CFIUS notices and negotiating mitigation agreements in the energy, semiconductor, telecommunications, aerospace and defense, and transportation sectors, among others.

Chase also represents clients in economic sanctions and export control matters, including issues related to the embargoes and other restrictions administered by the Office of Foreign Assets Control, as well as the International Traffic in Arms Regulations and the Export Administration Regulations. He has also counseled importers in all types of U.S. customs matters, and his trade remedy experience includes antidumping and countervailing duty matters, as well as additional duties imposed under Section 232 of the Trade Expansion Act of 1962 and Section 301 of the Trade Act of 1974.

Chase joined the firm as counsel in 2020 after more than 10 years of assisting clients in a range of sectors as a member of the international trade practices at other major international law firms. He became a partner in 2022.

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Notable Experience

  • Hanwha General Chemical Co., Ltd. in its acquisition of the aftermarket gas turbine business of Ansaldo Energia S.p.A. through equity purchase of eight entities in seven jurisdictions.

  • Western Digital in multiple matters including the sale of its ActiveScale business to Quantum; the sale of its IntelliFlash business to DataDirect Networks, Inc.; and its acquisition of Kazan Networks.

  • LORD Corporation in its $3.675 billion sale to Parker Hannifin. 

  • Grindr in its $608 million sale to San Vicente Acquisition LLC.

  • KKR in its recapitalization of and investment in Transphorm, Inc.

  • J.F. Lehman in its acquisition of Integrated Global Services.

  • Morgan Stanley Capital Partners portfolio company in its acquisition of iMark Molding.

  • Sumitomo Dainippon Pharma in its acquisition of late stage biopharma companies and the formation of an alliance with Roivant Sciences Ltd. worth $3 billion.

  • BBA Aviation in its sale of $1.365 billion its Ontic business.

  • PolyOne in the $1.5 billion acquisition of Clariant’s color and additive masterbatch business.

  • Ferro Corporation in the sale of its global tile coatings business to Lone Star Funds.

  • Directional Aviation Capital in its sale of a 50% interest in SIMCOM Holdings, Inc. to CAE Inc.

  • HOERBIGER Group in its acquisition of Deublin Company.

  • Parker Hannifin in its $1.725 billion all-cash acquisition of Exotic Metals Forming Company LLC.

  • Shiseido in its $845 million of acquisition of the Drunk Elephant brand and other assets.  

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Selected Activities

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  • Faculty; Financial Institutions, Markets, and Transactions Training Series; 2023

Publications

Contributing author, Cleary Foreign Investment and International Trade Watch blog

“Sanctions on Russian Securities Infrastructure Create Additional Hurdles to Divesting from Russia,” Cleary Foreign Investment and International Trade Watch (December 4, 2024)

“Treasury Issues Final Rule Enhancing CFIUS Mitigation and Enforcement Authority,” Cleary Foreign Investment and International Trade Watch (November 27, 2024)

“OFAC Sanctions Gazprombank, Continues to Target Russian Financial Sector and Foreign Financial Institutions,” Cleary Gottlieb Alert Memorandum (November 26, 2024)

“Russian Countermeasures: The Governmental Commission Tightens Conditions for Exits by Investors From Unfriendly Jurisdictions,” Cleary Gottlieb Alert Memorandum (November 4, 2024)

“Long-Awaited U.S. Outbound Investment Regime Published, Will Become Effective January 2, 2025,” Cleary Gottlieb Alert Memorandum (November 4, 2024)

“Price Cap Coalition Issues Updated Advisory for Maritime Oil Industry,” Cleary Foreign Investment and International Trade Watch (October 22, 2024)

“U.S., UK, and EU Sanctions Alignment: U.S. IT and Software Sector Service Bans and Export Controls Take Effect as Russia Sanctions Continue to Expand,” Cleary Foreign Investment and International Trade Watch (October 9, 2024)

“Commerce Takes Next Step in Furtherance of Import Prohibition on Connected Vehicles and Systems from China and Russia,” Cleary Foreign Investment and International Trade Watch (September 27, 2024)

“Commerce Imposes Export Controls on Quantum Computing and Other Advanced Technologies, Expands Scope of CFIUS Mandatory Filing Requirement,” Cleary Foreign Investment and International Trade Watch (September 9, 2024)

“CFIUS Releases 2023 Annual Report: Key Takeaways,” Cleary Foreign Investment and International Trade Watch (August 20, 2024)

“Treasury Takes Next Step on Implementation of Outbound Investment Regime, Clarifies Certain Aspects of Prior Proposal,” Cleary Foreign Investment and International Trade Watch (August 7, 2024)

“Treasury Issues Proposed Rule to Expand CFIUS Jurisdiction Over Real Estate Transactions Near Military Installations,” Cleary Foreign Investment and International Trade Watch (July 22, 2024)

“New Russian Decree Imposes Restrictions on Transfer of IP Rights,” Cleary Gottlieb Alert Memorandum (June 5, 2024)

“Potential Seizure of U.S. Assets in Russia,” Cleary Gottlieb Alert Memorandum (May 29, 2024)

“Statute of Limitations for U.S. Sanctions Violations Extended from Five to Ten years,” Cleary Foreign Investment and International Trade Watch (May 2, 2024)

“US and UK Tighten Restrictions on Trade and Use of Russian Metals,” Cleary Gottlieb Alert Memorandum (April 22, 2024)

“Treasury Issues Proposed Rule to Enhance CFIUS Mitigation and Enforcement,” Cleary Foreign Investment and International Trade Watch (April 15, 2024)

“Proposed New EU FDI Screening Regulation — 10 Things to Know,” Cleary Gottlieb Alert Memorandum (March 12, 2024)

“Updates to the Critical and Emerging Technologies List Signals Refinement of Focus,” Cleary Foreign Investment and International Trade Watch (February 29, 2024)

“United States” chapter, Lexology Panoramic: Foreign Investment Review 2024 (February 23, 2024)

“Impact of Recent U.S. Secondary Authority Targeting Foreign Financial Institutions Supporting Russia’s Military-Industrial Base,” Cleary Gottlieb Alert Memorandum, (February 22, 2024)

“EU Takes Time to Ready Outbound Investment Control Toolkit,” Cleary Gottlieb Alert Memorandum, (February 1, 2024)

“FDI Review Regimes are Well-Established and Active; Outbound Investment Regimes are on the Horizon,” Cleary Gottlieb Selected Issues for Boards of Directors in 2024 (January 17, 2024)

“Economic Sanctions: Developments and Lessons for Boards in 2024,” Cleary Gottlieb Selected Issues for Boards of Directors in 2024 (January 17, 2024)

“United States and Mexico to Bolster Cooperation in Foreign Direct Investment Screening,” Cleary Foreign Investment and International Trade Watch (December 12, 2023) 

“U.S. Government Unveils Proposal for Outbound Investment Regime Targeting China,” Cleary Gottlieb Alert Memorandum, (August 15, 2023)

“DOJ, Commerce, and Treasury Issue Advisory on Voluntary Self-Disclosure Policies,” Cleary Gottlieb Alert Memorandum, (August 1, 2023)

“Nationalization of Russian Assets of Investors From Unfriendly States Continues,” Cleary Gottlieb Alert Memorandum, (July 24, 2023)

“Dutch Foreign Direct Investment Screening Regime Enters Into Force,” Cleary Gottlieb Alert Memorandum (July 4, 2023)

“UK Russian Sanctions Expanded Following G7 Summit,” Cleary Gottlieb Alert Memo (May 23, 2023)

“Tit for Tat Continues, or Further Russian Countersanctions That Allow Nationalization of Assets of Persons From Unfriendly States,” Cleary Gottlieb Alert Memo (May 9, 2023)

“U.S. Supreme Court Holds FSIA Does Not Immunize Foreign Sovereigns From Criminal Prosecution,” Cleary Gottlieb Alert Memo (April 21, 2023)

“Outbound Investment Screening Regime—EU May Follow In U.S. Footsteps,” Cleary Foreign Investment and International Trade Watch (February 8, 2023)

“United States” chapter, Getting the Deal Through: Foreign Investment Review 2023 (February 3, 2023)

“PAIP Act Authorizes Sanctions for Trade Secret Theft by Chinese Actors,” Cleary Foreign Investment and International Trade Watch (January 17, 2023)

“Recent OFAC Actions Related to the Oil Sector,” Cleary Foreign Investment and International Trade Watch (January 6, 2023)

“Recent Developments Regarding the Maritime Services Ban on Russian-Origin Crude Oil and Petroleum Products (with Price Cap “Safe Harbor” or Exemption),” Cleary Foreign Investment and International Trade Watch (January 6, 2023)

“Potential Outbound Investment Screening Regime Receives Federal Funding,” Cleary Foreign Investment and International Trade Watch (January 4, 2022)

“OFAC and FinCEN Announce Joint Enforcement Action Against U.S.-Based Digital Asset Exchange,” Cleary Foreign Investment and International Trade Watch (October 25, 2022)

“The United States Tightens China-Related Export Controls on Advanced Computing and Semiconductor Manufacturing Items,” Cleary Foreign Investment and International Trade Watch (October 17, 2022) 

“3 Foreign Investment Issues Affecting Cross-Border Deals,” Law360 (September 12, 2022)

“New Export Controls on Semiconductor and Gas Turbine Engine Technologies Expand CFIUS Mandatory Notification Requirements,” Cleary Foreign Investment and International Trade Watch (August 29, 2022)

“Sanctions Compliance and Contingency Planning: Lessons From the Conflict in Ukraine,” Financier Worldwide (August 8, 2022)

“Global Merger Control and Foreign Direct Investment Considerations Associated with Cross-Border Transactions,” Competition Policy International (June 24, 2022)

“U.S. Federal Judge Finds Probable Cause for Conspiracy to Violate U.S. Sanctions and to Defraud the United States in First Published Opinion Discussing U.S. Sanctions Violations Involving Use of Cryptocurrency,” Cleary Foreign Investment and International Trade Watch (June 8, 2022)

“U.S. Government Reportedly Taking Steps Toward Limited Easing of Venezuela-Related Sanctions,” Cleary Foreign Investment and International Trade Watch (May 27, 2022) 

“Support for “Reverse CFIUS” Outbound Investment Screening Regime Grows,” Cleary Foreign Investment and International Trade Watch (March 31, 2022)

“Authorities in U.S. Take Steps to Strengthen Enforcement of U.S. Measures Against Russia,” Cleary Foreign Investment and International Trade Watch (March 10, 2022)

“Sanctions Developments Resulting From the Geopolitical Conflict in Ukraine,” Cleary Foreign Investment and International Trade Watch (February 23, 2022)

“United States” chapter, Getting the Deal Through: Foreign Investment Review 2022 (February 2, 2022)

“Global Economic Sanctions Regimes: Implications for Multinational Companies,” Corporate Disputes (January-March 2022) 

“Updates to the Critical and Emerging Technologies List Signal Additional Areas of Focus,” Cleary Foreign Investment and International Trade Watch (February 17, 2022)

“OFAC Imposes Sanctions on Belarusian Sovereign Debt, Announces New Designations,” Cleary Foreign Investment and International Trade Watch (December 3, 2021)

“OFAC Ramps up Targeting of Ransomware-linked Actors and FinCEN Updates Ransomware Advisory,” Cleary Foreign Investment and International Trade Watch (November 19, 2021)

“A Look Behind the CFIUS Non-Notified Process Curtain; How it Works and How to Handle Outreach From CFIUS,” Cleary Foreign Investment and International Trade Watch (October 4, 2021)

“Is Your U.S. Sponsored Private Equity Fund a Foreign Person for CFIUS Purposes?,” Cleary Foreign Investment and International Trade Watch (October 4, 2021) 

“OFAC Updates Ransomware Advisory and Sanctions Virtual Currency Exchange,” Cleary Foreign Investment and International Trade Watch (September 27, 2021) 

“CFIUS Threatens to Block Magnachip Deal; Shows Willingness to Interpret its Jurisdiction Broadly,” Cleary Foreign Investment and International Trade Watch (September 10, 2021) 

“CFIUS Releases 2020 Annual Report,” Cleary Foreign Investment and International Trade Watch (July 29, 2021) 

“China Passes “Anti-Foreign Sanctions Law”,” Cleary Foreign Investment and International Trade Watch (June 21, 2021)

“OFAC Revokes Key General License Under Belarus Sanctions Program,” Cleary Foreign Investment and International Trade Watch (April 26, 2021) 

“OFAC Settles With Digital Currency Payment Processor for Sanctions Violations,” Cleary Enforcement Watch (March 9, 2020)  

“United States Imposes Sanctions in Response to Military Coup in Myanmar,” Cleary Foreign Investment and International Trade Watch (February 16, 2020)

“United States” chapter, Getting the Deal Through: Foreign Investment Review 2021 (February 1, 2021) 

“Developments in U.S. Sanctions and Foreign Investment Regulatory Regimes,” Selected Issues for Boards of Directors in 2021 (January 11, 2021) 

“Current Status of Restrictions on Securities of Chinese Military Companies,” Cleary Gottlieb Alert Memo, (January 10, 2021)

“UK Proposes A Mandatory, Pre-Closing National Security Regime,” Cleary Gottlieb Alert Memo, (November 13, 2020) 

“Trump Administration Bans Transactions in Securities of Military-Linked Chinese Companies: Potentially Far-Ranging Consequences Remain Unclear,” Cleary Foreign Investment and International Trade Watch (November 13, 2020)

“What to Expect From the Biden Administration,” Cleary Gottlieb Alert Memo (November 9, 2020) 

“Venture Capital Investing: New NVCA Models, and New Challenges for Foreign Investors in Early-Stage U.S. Companies,” Cleary Gottlieb Alert Memo (October 7, 2020) 

“CFIUS Shifts Focus of ‘Critical Technology’ Mandatory Notifications to Export Controls,” Cleary Gottlieb Alert Memo (August 31, 2020)

“Ransomware and Sanctions Compliance: Considerations for Responses to Attacks,” Cleary Foreign Investment and International Trade Watch (September 14, 2020)

“BIS Issues Long-Awaited Request for Public Comment on Foundational Technologies,” Cleary Foreign Investment and International Trade Watch (August 31, 2020)

“BIS Further Tightens Export Restrictions on Huawei,” (co-author) Cleary Foreign Investment and International Trade Watch (August 21, 2020)

“President Trump Orders TikTok Divestment; Sweeping Order Appears to Indicate a Broadening of CFIUS’s Jurisdiction,” (co-author) Cleary Foreign Investment and International Trade Watch (August 21, 2020)

“Navigating Conflicts of Law: U.S. Sanctions and China’s National Security Law,” (co-author) Cleary Gottlieb Alert Memo (August 19, 2020)

“CFIUS Releases 2019 Annual Report,” (co-author) Cleary Foreign Investment and International Trade Watch (August 10, 2020)

“President Trump Authorizes Restrictions on WeChat and TikTok; Details to Come,” (co-author) Cleary Foreign Investment and International Trade Watch, August 7, 2020 

“United States Enacts Additional Hong-Kong Related Sanctions; Impact Remains Unclear,” (co-author) Cleary Foreign Investment and International Trade Watch, July 14, 2020

“New Syria-Related Sanctions Regulations Issued; Secondary Sanctions Authority Targeting Syria to Take Effect Soon,” (co-author) Cleary Foreign Investment and International Trade Watch, June 12, 2020

“CFIUS Blocks Joint Venture Outside the United States, Releases 2018-2019 Data, and Goes Electronic,” (co-author) Cleary Foreign Investment and International Trade Watch, June 3, 2020

“Proposed Rule Would Broaden CFIUS Mandatory Notification Requirements,” (co-author) Cleary Gottlieb Alert Memo, May 26, 2020

“COVID-19: CFIUS Considerations for Distressed M&A and Lending Transactions,” (co-author), Cleary Gottlieb Alert Memo, May 8, 2020

“CFIUS Imposes Filing Fees,” (co-author), Cleary Gottlieb Alert Memo, April 29, 2020

“BIS Tightens National Security Export Controls,” (co-author), Cleary Foreign Investment and International Trade Watch, April 29, 2020

“OFAC Issues Guidance on COVID’s Impact on Compliance and Enforcement,” (co-author), Cleary Foreign Investment and International Trade Watch, April 27, 2020; republished by New York University School of Law Compliance & Enforcement Blog.

“Latin America: Top Legal Concerns Facing General Counsel in 2020,” (co-author), Lexology, March 13, 2020

“Section 232 Update: Challenges to Steel and Aluminum Derivative Tariffs Are Succeeding,” (co-author), Lexology, March 13, 2020

“U.S. Imposes Tariffs on Derivative Steel and Aluminum Imports,” (co-author), Lexology, February 25, 2020

“Facing FIRRMA: Treasury Releases Final CFIUS Regulations, (co-author), Lexology, January 22, 2020

“U.S. to Review and Consider Additional Section 301 Tariffs Targeting the EU Over Trade Dispute,” (co-author), Lexology, December 17, 2019

“U.S. Proposes Up to 100 Additional Duties Due to French Digital Tax,” (co-author), Lexology, December 10 2019

“U.S.-China Trade Uncertainty: Section 301 Tariff State of Play,” (co-author), Lexology, November 22, 2019

“Facing FIRRMA: CFIUS Review of the Biotechnology and Life Sciences Sector,” (co-author), Lexology, October 30, 2019

“Facing FIRRMA: Proposed Regulations Expand Scope of CFIUS National Security Review Process,” (co-author), Lexology, September 27, 2019

“Staying Out of the Penalty Box - A Reminder Regarding the CFIUS Pilot Program,” (co-author), Lexology, June 12, 2019

“Navigating Multijurisdictional M&A,” (co-author), Corporate Counsel Business Journal, May 13, 2019

“How Chinese Investments Can Pass CFIUS Scrutiny,” (co-author), Columbia Blue Sky Blog, February 6, 2018

Events

Artificial Intelligence in the Boardroom: What Board and Senior Executives Need to Know

Lunch Workshop: The EU Foreign Subsidies Regulation – How to Get Ready (U.S. Edition)

EMTA Webinar: Progress on Venezuela?

The UK’s National Security Screening Regime: The First Six Months

3rd European Forum on FDI Reviews and CFIUS

International FDI Regimes: Comparing and Contrasting How to Do Business Across Multiple Nations and the Latest Developments on FDI Processes

EMTA Webinar: Update on Sanctions

FDI: Hot Relationships Between the U.S., EU, and UK

The UK’s New Investment Regime: Changes and Challenges

The New M&A Paradigm: Guiding Your Company in Today’s Global Environment - International Trade Regulation

CLE Academy: Section 232 and 301 Tariffs and Expanded CFIUS Review of Foreign Investments

Impact of FIRRMA on Private Equity Funds: Expanded CFIUS Review of Foreign Investments, New Filing Requirements

Staff-level Briefing on Trade Tools and Enforcement, Congressional US-China Working Group

Trends and Developments in International Trade: What You Need to Know