Les P. Carnegie

  • Partner
  • Eles.carnegie@lw.com
  • 555 Eleventh Street, NW
  • Suite 1000
  • Washington, D.C. 20004-1304
  • USA
  • T +1.202.637.1096


Les Carnegie advises companies, financial institutions, and private equity funds, both in the US and globally, on their outbound and inbound business transactions. He helps clients navigate US export controls, sanctions, and foreign investment reviews by CFIUS. He co-leads Latham’s Export Controls, Economic Sanctions & Customs Practice, and the CFIUS & US National Security Practice.

Mr. Carnegie advises clients on legal, policy, and enforcement issues arising under:

  • US trade and economic sanctions
  • US export controls
  • National security reviews of foreign investments in the US conducted by the Committee on Foreign Investment in the United States (CFIUS)

Mr. Carnegie draws on strong working relationships with regulators and two decades of legal experience to help clients understand legal restrictions and requirements, secure licensing, make voluntary disclosures and respond to enforcement actions, as well as maintain compliance with various US legal regimes, including:

  • National security reviews before CFIUS
  • US Treasury Department’s Office of Foreign Assets Control (OFAC)
  • US Department of State’s International Traffic in Arms Regulations (ITAR)
  • US Department of Commerce’s Export Administration Regulations (EAR), the Foreign Trade Regulations (FTR), and antiboycott regulations

He has developed particular insight on key strategic industries, including:

  • Banking and financial services
  • Energy
  • Life Sciences/Biotechnology
  • Aerospace/Defense
  • Consumer/Retail goods
  • Hospitality/Entertainment
  • Not-for-profit NGOs/Tax-exempt organizations

Mr. Carnegie frequently writes and speaks on sanctions and CFIUS topics. He is regularly recognized by Chambers USA and The Legal 500 US, and was named a Top Advisor by Foreign Investment Watch  in 2020. Clients describe him as “our first choice when tackling complex economic sanctions or export control compliance matters,” and “a tireless, engaging advocate and forward thinker,” whose “knowledge of US sanctions is excellent, as are his relationships with OFAC personnel.”

Mr. Carnegie organized and edited the first Foreign Direct Investment Regimes app, covering investment from several global jurisdictions.

He clerked for Judge Gerald B. Tjoflat of the US Court of Appeals for the Eleventh Circuit.


A sampling of Mr. Carnegie’s work includes representing:

Sanctions and Export Controls
  • Financial institutions regarding compliance with US sanctions in lending and capital markets transactions
  • Leading aerospace and defense companies regarding compliance with US export controls and US sanctions, including voluntary disclosures to the Treasury, Commerce, and State Departments
  • A leading energy firm, including oil exploration and production companies, as well as oil services companies regarding compliance on US export controls, US sanctions, and designing compliance programs, as well as voluntary disclosures to the Treasury and Commerce Departments
  • Leading high-technology companies, including 3-D printing companies, on compliance with US foreign trade controls
  • Several medical device and pharmaceutical companies in helping to secure government licensing for sales of humanitarian products to countries subject to US economic and trade sanctions
  • Leading not-for-profit organizations, including the International Committee for the Red Cross, CARE USA, Save the Children, and Mercy Corps, regarding compliance with US export controls and US sanctions, including securing export licensing and OFAC authorization
  • Integrated Device Technology, a leading supplier of analog mixed-signal products, including sensors, connectivity and wireless power, in its successful efforts to obtain CFIUS clearance in connection with its proposed acquisition by Japan-based Renesas Electronics, a premier supplier of advanced semiconductor solutions, in US$6.7 billion deal
  • Siemens AG, a German multinational company, in its successful effort to obtain CFIUS approval for its US$7.8 billion strategic acquisition of Dresser-Rand Group, a supplier of custom-engineered rotating equipment solutions
  • Novelis, the world leader in aluminum rolling and recycling, in its successful effort to obtain CFIUS clearance of its proposed US$2.6 billion acquisition of Aleris, a global supplier of rolled aluminum products
  • Atos SE, a global leader in digital transformation based in France, in its successful effort to obtain CFIUS clearance of its US$3.4 billion acquisition of Syntel, a US-based multinational provider of integrated technology and business services
  • Avago Technologies, a Singaporean semiconductor company, in its successful effort to obtain CFIUS approval in connection with its US$37 billion acquisition of Broadcom, a major manufacturer of telecommunications and networking equipment
  • Hytera Communications, a Chinese manufacturer and supplier of land mobile radio and digital mobile radio products, systems, and applications, in its successful effort to obtain CFIUS clearance to acquire the US business of Sepura, a UK company
  • Vision Technologies Aerospace, a maintenance and engineering group held by Singapore Technologies Engineering, in its successful effort to obtain CFIUS clearance in connection with its acquisition of MRA Systems, a unit of General Electric

Thought Leadership

  • New UK Sanctions and Export Controls Rules – Top 10 Takeaways -  December 23, 2020
  • Committee on Foreign Investment in the United States – Key Questions Answered On CFIUS -  December 16, 2020
  • UK Adopts Sanctions to Target Belarus Government Officials -  October 01, 2020
  • US Trade Controls Against China Reach Supply Chain and End-Use Targets and Activities -  August 19, 2020
  • UK Introduces Sanctions Regime Targeting Global Human Rights Offenders -  July 10, 2020
  • CFIUS Annual Report: 6 Key Takeaways for Calendar Year 2018 -  May 21, 2020
  • New CFIUS Filing Fees Now in Effect: 5 Key Takeaways -  May 04, 2020
  • UK Sanctions Authority Issues Record Penalty for Russia-Related Sanctions Violations -  April 02, 2020
  • How Final CFIUS Regulations Will Impact Technology Companies and Investors -  March 02, 2020
  • Final CFIUS Regulations Implementing FIRRMA Take Effect in February 2020: 10 Key Questions Answered -  January 22, 2020
  • Guide to Acquiring a US Public Company -  January 13, 2020
  • Department of Justice Revises Policy Regarding Voluntary Disclosures of Export Control and Sanctions Violations -  December 18, 2019
  • CFIUS Annual Report: 10 Key Takeaways for Calendar Years 2016 and 2017 -  November 27, 2019
  • US Treasury Department Publishes Proposed Regulations to Implement FIRRMA: 10 Key Questions Answered -  September 26, 2019
  • US Expands Venezuela Sanctions: Three Key Questions -  August 12, 2019
  • US Commerce Department Imposes Broad Export Control Restrictions on Huawei -  May 23, 2019
  • OFAC’s 5 Essential Components of an Effective Sanctions Compliance Program  -  May 09, 2019
  • 10 Things to Know: US Allows Lawsuits Relating to “Trafficking” in Confiscated Property in Cuba  -  May 03, 2019
  • OFAC Imposes Comprehensive Sanctions on Venezuela’s State Oil Company, PdVSA -  January 29, 2019
  • OFAC Adds Venezuela Media Company and Others to US Sanctions List -  January 08, 2019
  • Top 10 Things to Know About Expanded US Sanctions on Iran -  November 06, 2018
  • CFIUS Pilot Program Makes Notifications Mandatory for Specific Areas of Critical Technology  -  October 17, 2018
  • How FIRRMA Changes the Game for Tech Cos. and Investors -  October 10, 2018
  • New Law Governing Foreign Direct Investment in the United States Brings Significant Changes to CFIUS Review -  August 13, 2018
  • EU Responds to the Snap-Back of US Sanctions Against Iran: Between a Rock and a Hard Place -  August 09, 2018
  • Foreign Direct Investment in the United States and Europe -  July 30, 2018
  • Top 10 Things to Know About President Trump’s Decision to Withdraw from the Iran Nuclear Agreement -  May 10, 2018
  • House Passes Space Commerce Free Enterprise Bill to Increase US Support for Commercial Spaceflight -  May 07, 2018
  • Status of CFIUS Reform Legislation -  April 25, 2018
  • US Treasury Department’s New Designations Under the Russia-Related Sanctions: 3 Key Takeaways -  April 09, 2018
  • Включение новых лиц в санкционный список Казначейством США в рамках антироссийских санкций: три ключевых вывода -  April 09, 2018
  • Казначейство США выпустило ожидаемый список российских лиц в рамках ранее принятого законодательства -  February 01, 2018
  • US Treasury Department Issues Anticipated List of Russian Parties, Pursuant to Recent Legislation -  January 31, 2018
  • CFIUS Reconstructed: The Foreign Investment Risk Review Modernization Act of 2017 -  December 21, 2017
  • Venezuela Restructuring: A Long Road Ahead? -  November 08, 2017
  • 10 Takeaways From the CFIUS Annual Report to Congress -  October 02, 2017
  • The Trump Administration’s New Venezuela Sanctions: Top 10 Takeaways -  August 29, 2017
  • Ужесточение санкций в отношении России, Ирана и Северной Кореи: Десять ключевых положений -  August 08, 2017
  • Expanded Russia, Iran, and North Korea Sanctions: Top 10 Takeaways -  August 01, 2017
  • Cuba & Trump: What the Changes Mean -  June 21, 2017
  • Outbound Chinese Investment into the EU: What You Need to Know about Regulatory Roadblocks -  March 23, 2017
  • Among Final Actions, Obama Administration Suspends Core of US Sanctions Against Sudan -  January 30, 2017
  • US Department of Justice Guidance Seeks to Encourage Voluntary Self-Disclosure of Export Controls and Sanctions Violations -  November 14, 2016
  • Six Months After Implementation of Iran Nuclear Agreement: Top 10 Observations  -  August 1, 2016
  • 8 Key Takeaways From the CFIUS Annual Report to Congress -  February 26, 2016
  • Top 10 Things to Know About the Implementation of the Iran Nuclear Agreement -  January 19, 2016
  • Movement Towards Implementation of Iran Nuclear Agreement Brings Limited Easing of Sanctions Into Focus -  October 29, 2015
  • Private Equity Firms: Prepare For The BE-180 Survey -  October 29, 2015
  • Cuba Embargo: What New Rules Mean  -  September 23, 2015
  • Free Flow of Information: Exporting Telecommunications Items and Services to Cuba -  July 24, 2015
  • Top 10 Things to Know About the Easing of Sanctions Under the Iran Nuclear Agreement -  July 16, 2015
  • Top 10 Things to Know About the Future of Sanctions on Iran  -  April 27, 2015
  • Cuba Sanctions: 10 Important Changes -  February 18, 2015
  • Sanctions Update: Continuing Implementation of US Embargo of Crimea Region -  February 06, 2015
  • Cuba-Related Sanctions and Export Regulations: 10 Important Changes -  January 20, 2015
  • Top 10 Things to Know About President Obama’s Cuba-Related Announcement -  December 18, 2014
  • Managing Legal and Business Risks Under the Russia/Ukraine Sanctions -  November 06, 2014
  • 5 Compliance “Hot Spots” for Technology Companies Under Export Controls and Sanctions Laws -  October 23, 2014
  • Ukraine Crisis Update: US and EU Expand and Align Sanctions -  September 15, 2014
  • Ukraine Crisis Update: EU Enacts Sanctions Targeting Military Exports, Oil Sector and State-Owned Banks  -  July 31, 2014
  • Ukraine Crisis Update: US and EU Expand Sanctions, Restrict Certain Energy-Related Exports to Russia -  July 30, 2014
  • Ukraine Crisis Update: US Imposes New Sanctions on Major Russian Banks and Energy Companies -  July 18, 2014
  • International Arbitration Newsletter (June 2014) -  June 12, 2014
  • Ukraine Crisis Update: US and EU Expand Sanction Lists; US Imposes Export Restrictions -  April 29, 2014
  • A Changing Landscape for US Importers of Defense Articles -  April 11, 2014
  • Ukraine Crisis: US Expands Sanctions to Target Certain Russian Business Interests, Broadens Framework For Future Sanctions -  March 21, 2014
  • Ukraine Crisis Update: US and EU Expand Sanctions -  March 18, 2014
  • Ukraine Crisis: US and EU Respond with Targeted Sanctions -  March 07, 2014
  • Al-Mirsal Blog: Iran’s Nuclear Agreement Negotiations Ease Certain US and EU Sanctions -  February 13, 2014
  • Iran Nuclear Agreement Negotiation Advances Trigger Limited Easing of US and EU Sanctions -  January 28, 2014
  • CFIUS 2012 Annual Report Reveals Increase in Chinese Filings and Notice Withdrawals -  January 21, 2014
  • Iran Nuclear Agreement: Potential Easing of US and EU Sanctions -  November 27, 2013
  • US Export Controls and Economic Sanctions – What Companies Need to Know -  July 16, 2013
  • Q&A: New SEC Disclosure Requirements Take Effect -  February 07, 2013
  • US Sanctions Against Iran Continuing To Expand -  January 28, 2013
  • CFIUS Issues 2011 Annual Report -  January 18, 2013
  • Emerging Challenges Under Export Control Laws for the Aerospace and Defense Industry -  December 06, 2012
  • Additional EU Sanctions on Iran -  October 29, 2012
  • CFIUS Shows New Aggressiveness In Ordering Divestiture -  October 29, 2012
  • CFIUS Shows New Aggressiveness in Ordering Divestiture of Wind Energy Farms -  October 09, 2012
  • Expanding US Sanctions Against Iran Present Growing Risks and Challenges for US and Non-US Companies -  March 3, 2012
  • CFIUS Annual Report for 2010 Offers Insights into National Security Review of Foreign Investment into the United States -  December 12, 2011
  • Scope of US Sanctions Against Libya and Syria Defined Further by Treasury Department General Licenses -  September 12, 2011
  • US and EU Sanctions Continue to Evolve in Response to Events in the Middle East and North Africa -  September 1, 2011
  • New Export Control Rules on Dual and Third-Country Nationality Not Likely to Ease ITAR Compliance Burdens on Non-US Entities -  May 27, 2011
  • UN Sanctions Against Libya Adopted by EU and UK -  March 10, 2011
  • Broad US and UN Sanctions Freeze Libyan Assets and Restrict Dealings with the Qadhafi Regime -  February 28, 2011

“He is our first choice when tackling complex economic sanctions or export control compliance matters.”
“He has a unique ability to explain the laws and regulations to non-attorneys.”
“He has a breadth of knowledge about the ins and outs of US sanctions.”

Chambers USA 2018-2020
Bar Qualification
  • District of Columbia
  • JD, Duke University School of Law, 1999
    With Honors
  • LLM, Duke University School of Law, 1999
    With Honors
  • BA, Duke University, 1996
    With Honors
  • Aerospace, Defense & Government Services
  • Energy & Infrastructure
  • Healthcare & Life Sciences
  • French
  • White Collar Defense & Investigations
  • Litigation & Trial Practice
  • Export Controls, Economic Sanctions & Customs