Cravath Publishes Winter 2026 Issue of Alumni Journal

CFIUS and National Security

Drawing on deep government and cross border experience, Cravath provides comprehensive advice to U.S. and international companies, private equity and venture capital firms and other investors on the many complex issues raised by the Committee on Foreign Investment in the United States (CFIUS) and other matters involving national security. Our multidisciplinary team, which includes former White House, U.S. Treasury Department and U.S. Department of Justice senior officials, deftly manages national security concerns including risk management, trade restrictions, cybersecurity, crisis response, and civil and criminal investigations and enforcement actions across highly regulated and strategic sector.

CFIUS

Our CFIUS expertise is derived from a combination of representing our international clients, who often seek to acquire U.S. businesses as part of a global growth strategy, and our U.S. clients, who pursue opportunities with international investors, in transactions across every industry and involving every region of the world.

Clients rely on our expertise to help them navigate the regulatory aspects of cross-border mergers, acquisitions, dispositions, investments and other business transactions, including:

Identifying and assessing CFIUS risks and implications at the earliest stages of transaction planning;
Strategic counseling on whether a mandatory CFIUS filing is required or a voluntary notice to CFIUS is advisable;
Assisting clients in engaging with CFIUS regarding their transactions when appropriate;
Coordinating with local counsel and specialists in connection with non U.S. foreign direct investment (FDI) reviews to provide seamless global FDI coverage; and
Assessing implications of the DOJ’s “safe harbor” policy for national security law violations disclosed during mergers and acquisitions.

National Security

We advise clients on the many complex issues and across several key areas implicated by national security considerations, including:

Anti-money Laundering: Our team advises financial institutions, digital asset businesses and other companies on compliance with AML/CTF laws and other aspects of the Bank Secrecy Act (BSA), as well as regulatory examinations and enforcement matters before U.S. and foreign regulators. We perform counterparty and transaction due diligence and assist with the development of internal controls to prevent potential corruption-related problems before they arise and to minimize potential exposure.
Cybersecurity: We stay on top of cutting-edge advancements in artificial intelligence, fintech, infrastructure and other technologies to anticipate and address the full range of issues arising in cybersecurity matters, including those with a national security dimension. Cravath handles incident response coordination, post‑breach investigations and litigation, and compliance matters, and helps our clients navigate interactions with U.S.‑based and foreign regulatory and enforcement authorities.
Investigations and Regulatory Enforcement: Cravath advises clients regarding the full range of corporate crises, regulatory enforcement proceedings and white collar matters, including matters involving the material support laws, cartel designations and the Anti-Terrorism Act. We routinely lead sensitive internal investigations and represent companies and individuals in connection with complex government investigations; defend these clients in parallel or related regulatory or civil litigations that can arise from investigations; and perform compliance risk assessments and design compliance programs that meet DOJ and SEC standards.
Sanctions & Export Controls: We counsel domestic and multinational companies on compliance with U.S. international trade regimes, transactional structuring and risk assessment. We conduct sensitive internal investigations and represent clients in remediation, disclosure, licensing and other matters involving enforcement authorities, including the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and U.S. Department of Commerce’s Bureau of Industry and Security (BIS).

CFIUS

Clients rely on our expertise to help them navigate the regulatory aspects of cross-border mergers, acquisitions, dispositions, investments and other business transactions, including:

Identifying and assessing CFIUS risks and implications at the earliest stages of transaction planning;
Strategic counseling on whether a mandatory CFIUS filing is required or a voluntary notice to CFIUS is advisable;
Assisting clients in engaging with CFIUS regarding their transactions when appropriate;
Coordinating with local counsel and specialists in connection with non U.S. foreign direct investment (FDI) reviews to provide seamless global FDI coverage; and
Assessing implications of the DOJ’s “safe harbor” policy for national security law violations disclosed during mergers and acquisitions.

National Security

We advise clients on the many complex issues and across several key areas implicated by national security considerations, including:

Anti-money Laundering: Our team advises financial institutions, digital asset businesses and other companies on compliance with AML/CTF laws and other aspects of the Bank Secrecy Act (BSA), as well as regulatory examinations and enforcement matters before U.S. and foreign regulators. We perform counterparty and transaction due diligence and assist with the development of internal controls to prevent potential corruption-related problems before they arise and to minimize potential exposure.
Cybersecurity: We stay on top of cutting-edge advancements in artificial intelligence, fintech, infrastructure and other technologies to anticipate and address the full range of issues arising in cybersecurity matters, including those with a national security dimension. Cravath handles incident response coordination, post‑breach investigations and litigation, and compliance matters, and helps our clients navigate interactions with U.S.‑based and foreign regulatory and enforcement authorities.
Investigations and Regulatory Enforcement: Cravath advises clients regarding the full range of corporate crises, regulatory enforcement proceedings and white collar matters, including matters involving the material support laws, cartel designations and the Anti-Terrorism Act. We routinely lead sensitive internal investigations and represent companies and individuals in connection with complex government investigations; defend these clients in parallel or related regulatory or civil litigations that can arise from investigations; and perform compliance risk assessments and design compliance programs that meet DOJ and SEC standards.
Sanctions & Export Controls: We counsel domestic and multinational companies on compliance with U.S. international trade regimes, transactional structuring and risk assessment. We conduct sensitive internal investigations and represent clients in remediation, disclosure, licensing and other matters involving enforcement authorities, including the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and U.S. Department of Commerce’s Bureau of Industry and Security (BIS).

Deals & Cases
Recent News & Insights

Deals & Cases

December 09, 2025

Paramount’s $108.4 Billion All‑Cash Tender Offer to Acquire Warner Bros. Discovery, Inc.

On December 8, 2025, Paramount, a Skydance Corporation (“Paramount”), announced it has commenced an all-cash tender offer to acquire all of the outstanding shares of Warner Bros. Discovery, Inc. (“WBD”) for $30.00 per share in cash, equating to an enterprise value of $108.4 billion. Paramount’s proposed transaction is for the entirety of WBD, including the Global Networks segment. Cravath is representing Paramount in connection with the transaction.

Activities

May 06, 2026

Nicole Argentieri Featured in the ABA’s Global Anti‑Corruption Committee Monthly Newsletter

On May 4, 2026, Cravath partner Nicole M. Argentieri was featured in the American Bar Association’s Global Anti‑Corruption Committee monthly newsletter, which highlighted her tenure at the U.S. Department of Justice, including as Acting Assistant Attorney General and Head of the Criminal Division, as well as her current work advising boards and companies on an increasingly dynamic enforcement landscape. In the Q&A, Nicole discussed navigating heightened risks in anti‑money laundering and national security, noting that she strives to provide a practical perspective to clients so they can understand the shifts in enforcement priorities and resources at the DOJ. Reflecting on her career and her favorite historical figure, Abraham Lincoln, Nicole described the importance of resilience and investing in personal relationships to sustain a demanding legal career, advising junior attorneys that “to be good at your job, you must invest in your relationships and stay connected to the people and causes that matter most to you.”

Activities

April 17, 2026

Evan Norris Speaks about Cartel Risk at ICC Mexico and Anticorruption Commission’s IX Anticorruption Postgraduate Course

On March 19, 2026, Cravath partner Evan Norris participated in the International Chamber of Commerce Mexico and the Anticorruption Commission’s IX Anticorruption Postgraduate Course, hosted in collaboration with Universidad Panamericana. The course brought together high‑level government officials, legal scholars and practitioners for sessions on combatting national and global corruption. Evan’s session was entitled “Beyond the FCPA: Evolving U.S. Approach to Cartel‑Related Bribery and Extortion” and focused on the compliance and enforcement risks for companies in the Americas with potential exposure to criminal groups recently designated by the U.S. State Department as foreign terrorist organizations.

Activities

April 15, 2026

Nicole Argentieri Speaks at the NYU Program on Corporate Compliance and Enforcement’s Spring Compliance Conference

On April 14, 2026, Cravath partner Nicole M. Argentieri participated in the NYU Program on Corporate Compliance and Enforcement’s Spring Compliance Conference. The conference discussed how companies should account for enhanced risk related to the Department of Justice’s focus on cartels, money laundering, government fraud and whistleblowers and how compliance programs should address the changing enforcement landscape. Nicole’s panel was entitled “One Year In: What Lessons Do the Trump Administration’s Enforcement Actions Have for Corporate Compliance Programs?”

Activities

March 16, 2026

Nicole Argentieri Moderates Sessions at the American Bar Association’s 2026 White Collar Crime Institute

Cravath partner Nicole M. Argentieri participated in the American Bar Association’s 2026 White Collar Crime Institute, which was held from March 10‑13, 2026, in San Diego, California. The event featured sessions with leading practitioners, in‑house counsel, judges, academics and enforcement officials on pressing legal, regulatory and ethical issues impacting the white collar landscape today, covering topics including cybersecurity, cryptocurrencies, money laundering, international law and other critical areas shaping the practice.

Activities

December 05, 2025

Nicole Argentieri Co‑Chairs ACI’s 42nd Annual Conference on FCPA and Global Anti‑Corruption

Cravath partner Nicole M. Argentieri participated in the American Conference Institute’s 42nd Annual Conference on FCPA and Global Anti‑Corruption, which was held from December 3‑4, 2025 in Washington, D.C. Nicole, who co‑chaired the conference, led a fireside chat with the Acting Assistant Attorney General for the Criminal Division Matt Galeotti about the Division’s priorities and revised policies. Nicole also interviewed Emma Luxton, the Director of Operations for the UK Serious Fraud Office about recent updates to SFO’s corporates guidelines and case announcements, and introduced Deputy Attorney General Todd Blanche, who gave his first speech on the state of white collar enforcement.

Deals & Cases

December 09, 2025