Tony Busch

Tony Busch advises companies navigating the increasingly complex intersection of international trade, national security, and technology regulation. Tony represents clients in many industries, including medical devices, telecommunications, energy, and the artificial intelligence/high-performance computing ecosystem.

Tony's work spans export controls, sanctions, inbound foreign investment reviews, outbound investment controls, and data security requirements, representing clients before the Bureau of Industry and Security (BIS), the Office of Foreign Assets Control (OFAC), the Committee on Foreign Investments in the United States (CFIUS), the Office of Investment Security (OIS), and the US Department of Justice (DOJ). His experience includes obtaining export and sanctions licenses; preparing commodity classifications, advisory requests, and de-listing petitions; conducting internal investigations; managing voluntary self-disclosures; developing compliance programs; and advising on Entity List, Military End-User List, SDN List, and other restricted-party issues, including under the BIS Affiliates Rule.

Tony has advised on regulatory risks associated with hundreds of mergers and acquisitions, private equity investments, joint ventures, financings, and other strategic transactions. For over 150 of those deals, Tony conducted due diligence with respect to the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), various OFAC sanctions programs, customs, anti-corruption and anti-bribery, CFIUS, the Outbound Investment Security Program (OISP), the DOJ Data Security Program (DSP), and Defense Counterintelligence and Security Agency (DCSA) foreign ownership, control, or influence (FOCI) considerations, as applicable.