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On July 25, 2023, the Senate voted 91 to 6 to approve the Outbound Investment Transparency Act as an amendment to the National Defense Authorization Act. The legislation was proposed by Sens. John Cornyn (R-TX) and Bob Casey (D-PA). It would require companies to disclose investments or acquisitions involving entities in China, Russia, Iran, and North Korea in six key technology sectors.

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Tags: China, GT Insight, National Defense Authorization Act, NDAA, Outbound Investment Review, trade
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Photo of Kara M. Bombach Kara M. Bombach

Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and

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Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Russia), entities and individuals. In cases of foreign investment in the United States, Kara advises on the Exon-Florio provisions relating to U.S. national security concerns. She represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations.

Kara regularly represents clients in matters before U.S. government agencies, including the U.S. Departments of Commerce, State, Treasury and Defense. Kara has significant experience representing individuals and entities before OFAC in delisting matters and challenges to OFAC sanctions designations.

She advises national and multi-national companies (including Fortune® 5) on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anti-corruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.

Kara also counsels international not-for-profit and relief/aid organizations on best practices in economic sanctions, trade, and anti-corruption compliance issues that arise in their global operations, frequently in challenging and austere environments. She has provided legal services to organizations such as Save the Children (US), ONE Campaign, Mercy Corps, the International Committee of the Red Cross, Not on Our Watch/The Sentry, and The Enough Project.

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Photo of Robert Mangas Robert Mangas

Rob is a shareholder in the firm’s Federal Government Law & Policy group. He has represented clients before Congress and federal agencies from a variety of industries and in a number of policy areas, including trade, energy, environment, health care, biotechnology, transportation, financial…

Rob is a shareholder in the firm’s Federal Government Law & Policy group. He has represented clients before Congress and federal agencies from a variety of industries and in a number of policy areas, including trade, energy, environment, health care, biotechnology, transportation, financial services, manufacturing, tax, pensions, defense, and foreign relations. Rob has a depth of understanding of the rules of the U.S. Senate and House of Representatives, and he has deep experience in legislative drafting. He previously served as chief of staff to U.S. Senator Wendell Ford, the former Senate Majority Whip.

Concentrations

  • Health care
  • Energy
  • Biotechnology
  • Manufacturing
  • Foreign affairs
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Photo of Eleanor M. Ross Eleanor M. Ross

Eleanor (Elle) Ross advises government contractors from a diverse range of industries on regulatory matters including compliance with government regulations, contract disputes, defense of claims, and government investigations. She litigates bid protests before the Court of Federal Claims and the Government Accountability Office.

Eleanor (Elle) Ross advises government contractors from a diverse range of industries on regulatory matters including compliance with government regulations, contract disputes, defense of claims, and government investigations. She litigates bid protests before the Court of Federal Claims and the Government Accountability Office. She advises clients in connection with an array of agreements and multi-award procurements, including challenging award decisions in a variety of fora.

Elle also counsels clients on federal and state compliance obligations, particularly in connection with cybersecurity (including CMMC and NIST requirements) and supply chain risk management practices. She works with clients to understand government regulations and to develop compliance plans and to implement those plans. She also assists with making mandatory and voluntary disclosures to federal agencies and represented clients in subsequent investigations and administrative proceedings. She manages sanctions proceedings against contractors, including cases alleging fraud and corruption.

Elle also represents clients in commercial contract disputes, both in mediation and in federal court.

Previously, Ms. Ross was a legal consultant to World Bank Office of Suspension and Debarment, where she reviewed cross-border investigations to determine contractor compliance with World Bank regulations.

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