Areas of Practice
  • Georgetown University Law Center, J.D., 1996, magna cum laude, Order of the Coif, Senior Articles Editor, Georgetown Law Journal, Olin Fellow in Law and Economics
  • Stanford University, A.B., 1993, with honors
Bar & Court Admissions
  • District of Columbia
  • Maryland

Stephen Heifetz

1330 Connecticut Avenue, NW
Washington DC 20036
TEL: +1 202 429 6227
FAX: +1 202 429 3902
Steptoe International Compliance Blog

Stephen Heifetz helps clients navigate laws and policies at the nexus of international business and security. Much of his practice involves the Committee on Foreign Investment in the United States (CFIUS) and Foreign Ownership, Control, and Influence (FOCI) processes, along with economic sanctions and anti-money laundering rules, and other regulated, cross-border movements of money, people, goods, and services. Drawing on his experience at the Department of Justice (DOJ), the Department of Homeland Security (DHS), and the CIA, he counsels clients on legal compliance and political risk, conducts internal investigations, and defends against government investigations and enforcement actions. 

Stephen is one of few attorneys in private practice who has served in the US government on CFIUS and has been involved in the evolution of the Committee through changes in presidential administrations. He helps clients decide whether a transaction warrants filing with CFIUS and guides parties through the CFIUS process. Stephen similarly supports clients in matters involving the Defense Department’s National Industrial Security Program (NISPOM) and its FOCI rules, the Team Telecom process, and analogous national security reviews. 

Stephen also handles matters involving economic sanctions administered by the Office of Foreign Assets Control (OFAC) and by the UN Security Council, as well as anti-money laundering laws administered by FinCEN and other financial regulators. His practice further involves a range of other national security and foreign policy matters affecting cross-border movements, including travel facilitation programs administered by DHS, particularly the Visa Waiver Program (VWP), Global Entry, the Customs-Trade Partnership Against Terrorism (C-TPAT), and cargo and passenger screening rules administered by the Transportation Security Administration (TSA) and Customs and Border Protection (CBP). He is well-versed in the SAFETY Act and other private sector counter-terrorism programs, anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA), and codes of conduct applicable to private security providers. He has deep understanding of security rules related to visa processing, which are administered by the Bureau of Consular Affairs in conjunction with an array of US security agencies, and he routinely interfaces with US intelligence and security establishments. 

Stephen is co-chair of Steptoe’s International Regulation & Compliance Group. He has been published extensively in trade journals, law reviews, and newspapers, including The New York Times and The Washington Post.

Representative Matters

  • Helped obtain CFIUS clearances during the Trump administration for deals involving companies from China, Singapore, Japan, Europe, and elsewhere. Some of these matters involved state-owned enterprises and some involved negotiation of mitigation measures to facilitate CFIUS clearance. The value of the deals ranges from approximately $3 billion to $10 million.
  • Handled hundreds of CFIUS cases during the Obama and Bush administrations, including cases referred for decision by the President.
  • Negotiated FOCI mitigation agreements on behalf of European and Asian clients to permit US government contractors to continue classified work notwithstanding foreign ownership.
  • Involved in multiple “de-listing” matters to remove clients from various US government economic sanctions (i.e., “blacklists”), including the successful removal of a Belarusian bank.
  • Represented private security contractors with regard to UN sanctions matters, including Somalia’s Puntland government and Sterling Corporate Services, a counter-piracy project that garnered significant media coverage
  • Negotiated settlement of multiple TSA enforcement actions against freight forwarders, airline contractors, and employees of contractors.


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