Paul M. Rosen

Paul Rosen, former Assistant Secretary of the US Department of Treasury for Investment Security, leverages his experience leading the Committee on Foreign Investment in the United States (CFIUS) and developing the Outbound Investment Security Program to help clients navigate their most significant and complex regulatory, investigations, and enforcement matters, particularly those arising from cross-border transactions.

With nearly 15 years of legal, policy, and management experience across all three branches of government, Paul advises corporate and private equity clients on:

• Complex cross-border transactions, with a particular emphasis on investment security and regulatory matters
• White collar criminal defense
• Internal and cross-border investigations
• Compliance, investigations, and enforcement matters stemming from regulatory programs such as CFIUS, the Outbound Investment Security Program, and the DOJ Data Security Program’s bulk sensitive data rule

Combining his diverse and complementary experiences across government and private practice, Paul deftly guides clients on national security and crisis management challenges across industries including:

• Aerospace, defense, and government services
• Artificial intelligence
• Energy and infrastructure
• Financial institutions
• Technology

In May 2022, the US Senate confirmed him with bipartisan support to serve as Assistant Secretary of the US Department of Treasury for Investment Security. Paul oversaw CFIUS, leading day-to-day operations and handling hundreds of transaction filings that amounted to hundreds of billions of dollars and shaped US investment security and national security policy. In addition to managing hundreds of CFIUS filings annually, Paul revamped CFIUS’s compliance and enforcement function and oversaw a record number of CFIUS penalty and enforcement actions. He also led the drafting and implementation of the new outbound investment review and enforcement program. Paul testified before Congress numerous times on these and other important national security and investment policy issues.

Earlier in his career, Paul served in other high-profile roles in the US government, including as Chief of Staff at the US Department of Homeland Security and in several roles at the US Department of Justice, including as counsel to the Assistant Attorney General for the Criminal Division, and as a federal prosecutor in the Criminal Fraud Section, where he investigated and prosecuted complex financial crimes. Paul also served as Counsel on the Senate Judiciary Committee and clerked for US District Judge Gary Allen Fees (ret.) in the Central District of California.

While in government, Paul earned several awards, including the Distinguished Service Medal from the DHS — the highest honor bestowed by the secretary to recognize exceptional and transformational public service.

Paul also worked as a partner at another international law firm where he led its national security practice.