Stephen previously served in the U.S. government as a CFIUS official, and in other national security positions at the CIA, Department of Homeland Security, and Department of Justice.
For two decades, Stephen has been involved in thousands of CFIUS matters. He helps U.S. companies and foreign investors assess CFIUS risks, draft risk-allocation language, respond to CFIUS inquiries and enforcement actions, make CFIUS filings, and obtain CFIUS clearances. He also serves as CFIUS counsel to the National Venture Capital Association and has been recognized as a leading CFIUS and national security expert by Chambers USA, Chambers Global, Foreign Investment Watch, and Washingtonian.
Stephen has advised clients on regulatory compliance, investigations, and defense of government enforcement actions relating to anti-money laundering and beneficial ownership requirements, economic sanctions (including UN sanctions regimes), and an array of other national security matters.
Stephen has published articles in many forums, including The New York Times, The Washington Post, Bloomberg, Semafor, Lawfare, The Hill, and Law360, and he speaks regularly on CFIUS and other national security topics.
Stephen Heifetz is a partner in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where he advises clients on laws and policies at the intersection of international business and national security. He has been a CFIUS practitioner for two decades, and has previously served for the U.S. government on the Committee on Foreign Investment in the United States (CFIUS) as well as the National Venture Capital Association (NVCA). He has been involved in thousands of CFIUS matters and has been recognized as a leading CFIUS and national security expert by Chambers USA, Chambers Global, Foreign Investment Watch, and Washingtonian.
Stephen regularly helps U.S. companies and foreign investors determine whether to make a CFIUS filing, allocate CFIUS risk in transaction documents, navigate the CFIUS process, respond to CFIUS “non-notified” inquiries, and negotiate risk mitigation measures if needed to obtain CFIUS clearance. He advises clients on matters of legal compliance and political risk and defends companies facing investigations and government enforcement actions. He also represents clients with regard to anti-money laundering laws and beneficial ownership requirements administered by the Financial Crimes Enforcement Network (FinCEN) and other financial regulators, particularly laws pertaining to money transmitters and other money services businesses.
Additionally, Stephen advises on economic sanctions administered by the Office of Foreign Assets Control (OFAC) and by the UN Security Council, and has experience with anti-corruption and export control laws, with security screening rules applicable to visa applicants as well as airlines and other transportation companies, and with codes of conduct applicable to private security providers.
Prior to joining Wilson Sonsini, Stephen was a partner at a multinational law firm based in Washington, D.C., where he co-chaired that firm's international regulation and compliance group. From 2006 to 2010, he served as a senior official in the U.S. Department of Homeland Security's (DHS) Office of Policy Development. In this role, he served as DHS's daily representative to CFIUS and also worked with DHS's agencies—including the Transportation Security Administration, U.S. Customs and Border Protection, and U.S. Immigration and Customs Enforcement—to develop policies on a range of issues.
After finishing law school, Stephen worked for the Central Intelligence Agency and later served as a trial attorney in the U.S. Department of Justice's Money Laundering and Asset Recovery Section.
Stephen has published articles in top business and legal media outlets, including The New York Times, The Washington Post, Bloomberg, Semafor, Lawfare, The Hill, and Law360. He also was previously an adjunct professor at Georgetown University Law Center.
Stephen Heifetz is a partner in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where he advises clients on laws and policies at the intersection of international business and national security. He has been a CFIUS practitioner for two decades, and has previously served for the U.S. government on the Committee on Foreign Investment in the United States (CFIUS) as well as the National Venture Capital Association (NVCA). He has been involved in thousands of CFIUS matters and has been recognized as a leading CFIUS and national security expert by Chambers USA, Chambers Global, Foreign Investment Watch, and Washingtonian.
Stephen regularly helps U.S. companies and foreign investors determine whether to make a CFIUS filing, allocate CFIUS risk in transaction documents, navigate the CFIUS process, respond to CFIUS “non-notified” inquiries, and negotiate risk mitigation measures if needed to obtain CFIUS clearance. He advises clients on matters of legal compliance and political risk and defends companies facing investigations and government enforcement actions. He also represents clients with regard to anti-money laundering laws and beneficial ownership requirements administered by the Financial Crimes Enforcement Network (FinCEN) and other financial regulators, particularly laws pertaining to money transmitters and other money services businesses.
Additionally, Stephen advises on economic sanctions administered by the Office of Foreign Assets Control (OFAC) and by the UN Security Council, and has experience with anti-corruption and export control laws, with security screening rules applicable to visa applicants as well as airlines and other transportation companies, and with codes of conduct applicable to private security providers.
Prior to joining Wilson Sonsini, Stephen was a partner at a multinational law firm based in Washington, D.C., where he co-chaired that firm's international regulation and compliance group. From 2006 to 2010, he served as a senior official in the U.S. Department of Homeland Security's (DHS) Office of Policy Development. In this role, he served as DHS's daily representative to CFIUS and also worked with DHS's agencies—including the Transportation Security Administration, U.S. Customs and Border Protection, and U.S. Immigration and Customs Enforcement—to develop policies on a range of issues.
After finishing law school, Stephen worked for the Central Intelligence Agency and later served as a trial attorney in the U.S. Department of Justice's Money Laundering and Asset Recovery Section.
Stephen has published articles in top business and legal media outlets, including The New York Times, The Washington Post, Bloomberg, Semafor, Lawfare, The Hill, and Law360. He also was previously an adjunct professor at Georgetown University Law Center.
Author, “CFIUS Clampdown Will Deter Allied-Country Investment,” Law360, July 25, 2023
Co-author, “Treasury Risk Assessment Emphasizes That Decentralized Crypto Companies Have AML and Sanctions Compliance Obligations,” Wilson Sonsini Alert, April 25, 2023
Co-author with T. Jenkins, M. Casey, and J. Davey, “Final Regulations on Beneficial Ownership Will Require ‘Tens of Millions’ of Legal Entities to File Reports,” Wilson Sonsini Alert, October 4, 2022
Co-author with J. Davey and T. Jenkins, "Money Services Businesses Penalized for Failure to Adopt Robust Anti-Money Laundering Practices," Wilson Sonsini Alert, August 18, 2022
Co-author with J. Gruenspecht and N. Dhir, "A Tale of Two Filers: CFIUS Report Touts Efficiency, Also Indicates CFIUS Failed to Meet Statutory Deadlines for a Large Percentage of Filed Notices," Wilson Sonsini Bylined Article, August 17, 2022
Guest Opinion Columnist, "It's all China and Russia: CFIUS expert says it's tiem to 'get real,'" Foreign Investment Watch, August 13, 2022
Co-author with J. Gruenspecht, "Proposed Legislation Seeks to Create 'Reverse CFIUS': National Security Review of Outbound Activity Benefiting Entities or Countries of Concern," Wilson Sonsini Advisory, August 8, 2022
Co-author with M. Casey and J. Gruenspecht, "BEIS Blocks First Transaction Under the UK’s National Security and Investment Act," Wilson Sonsini Alert, August 1, 2022
Co-author with T. Jenkins, "Headed to the Metaverse? Be 'The One' to Minimize Money Laundering Risk," Wilson Sonsini Advisory, July 14, 2022
Co-author with M. Casey and J. Gruenspecht, "BEIS Publishes First Annual Report Regarding the UK's National Security and Investment Act," Wilson Sonsini Alert, July 5, 2022
Co-author with A. Caiazza, J. Kaplan, J. Hartwig, J. Davey, and T. Jenkins, "No Foolish Transactions: A Few Guidelines for NFT Marketplace Participants to Mitigate Anti-Money Laundering Risks," Wilson Sonsini Advisory, May 23, 2022
Co-author with J. Davey, N. Dhir, and J. Gruenspecht, “CFIUS Rules: A Crash Course in Assessing and Navigating Risk,” Practical Guidance, March 2022
Co-author with M. Alioto, A. Caiazza, and T. Jenkins, "President Biden Signs Executive Order on Ensuring Responsible Development of Digital Assets," Wilson Sonsini Advisory, March 15, 2022
Co-author with T. Jenkins and J. Kaplan, "Is Regulation of NFTs to Combat Financial Crime on the Horizon?" Wilson Sonsini Alert, February 23, 2022
Author, “Enhanced CFIUS Rules Have Lawyers Pushing Benefits of Foreign Investment,” The National Law Journal, February 23, 2022
Co-author with M. Casey and J. Gruenspecht, "The UK’s National Security and Investment Act Now Fully in Force," Wilson Sonsini Alert, January 4, 2022
Co-author with M. Casey, J. Davey, J. Gruenspecht, and T. Jenkins, "New Rules Will Require Beneficial Ownership Reporting to Federal Regulators by U.S. and Foreign Corporations, LLCs, and Other Legal Entities," Wilson Sonsini Alert, January 4, 2022
Co-author with M. Casey, J. Davey, J. Hartwig, and T. Jenkins, "New OFAC Guidance Raises the Stakes for Crypto Industry," Wilson Sonsini Alert, October 20, 2021
Author, “Policing of foreign tech investment in the US is broken. Here’s how to fix it.” Protocol, October 4, 2021
Co-author with J. Davey and J. Kaplan, "Anonymity Becomes Passé: U.S. Government Moves to Require Ownership Information for Corporations, LLCs, and Others," Wilson Sonsini Alert, April 15, 2021
Co-author with S. Cowell and J. Gruenspecht, "Companies That Procure IT Products or Services from China, Russia, and Certain Other "Adversary" Nations May Face New National Security Questions Under the Now-Effective "ICTS" Rule," Wilson Sonsini Alert, March 25, 2021
Co-author with J. Kaplan, J.E. Krosnicki, and C. Wang, "MSB or Not MSB? That Is the Question (for Determining Applicability of Anti-Money Laundering Rules)," Wilson Sonsini Alert, January 25, 2021
Co-author, National Security Regulations 2020 Year in Review, Wilson Sonsini, December 17, 2020
Co-author with J. Kaplan, "New Anti-Money Laundering Legislation Will Create Significant Transparency Compliance Requirements for Businesses and Investors," Wilson Sonsini Alert, December 14, 2020
Co-author with J.F. Gruenspecht, J.R. Davey, and N. Dhir, "CFIUS After FIRRMA Implementation: A Crash Course in Assessing and Navigating Risk," Wilson Sonsini Alert, October 15, 2020
Co-author with J.I. Aiello LeBeau, A.E. Seymour, M.B. Mannino, and J.F. Gruenspecht, "As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat," Wilson Sonsini Alert, September 21, 2020
Co-author with A.E. Seymour and J.F. Gruenspecht, "Executive Orders on TikTok and WeChat: Ambiguity and a Few Other Takeaways," Wilson Sonsini Alert, August 7, 2020
Speaker, “The Expansion of Investment Screening: Implications for Business and Investors,” Committee on Foreign Relations, March 24, 2022
Speaker, “How to Adapt to the New National Security Review Law for Foreign Investment in US Technology Companies,” The Japan Society of Northern California and JETRO, Webinar, October 7, 2021
Speaker, "U.S. and UK Venture Investment and National Security: A Joint Discussion with CFIUS and BEIS," Wilson Sonsini Events, April 21, 2021
Author, “CFIUS Clampdown Will Deter Allied-Country Investment,” Law360, July 25, 2023
Co-author, “Treasury Risk Assessment Emphasizes That Decentralized Crypto Companies Have AML and Sanctions Compliance Obligations,” Wilson Sonsini Alert, April 25, 2023
Co-author with T. Jenkins, M. Casey, and J. Davey, “Final Regulations on Beneficial Ownership Will Require ‘Tens of Millions’ of Legal Entities to File Reports,” Wilson Sonsini Alert, October 4, 2022
Co-author with J. Davey and T. Jenkins, "Money Services Businesses Penalized for Failure to Adopt Robust Anti-Money Laundering Practices," Wilson Sonsini Alert, August 18, 2022
Co-author with J. Gruenspecht and N. Dhir, "A Tale of Two Filers: CFIUS Report Touts Efficiency, Also Indicates CFIUS Failed to Meet Statutory Deadlines for a Large Percentage of Filed Notices," Wilson Sonsini Bylined Article, August 17, 2022
Guest Opinion Columnist, "It's all China and Russia: CFIUS expert says it's tiem to 'get real,'" Foreign Investment Watch, August 13, 2022
Co-author with J. Gruenspecht, "Proposed Legislation Seeks to Create 'Reverse CFIUS': National Security Review of Outbound Activity Benefiting Entities or Countries of Concern," Wilson Sonsini Advisory, August 8, 2022
Co-author with M. Casey and J. Gruenspecht, "BEIS Blocks First Transaction Under the UK’s National Security and Investment Act," Wilson Sonsini Alert, August 1, 2022
Co-author with T. Jenkins, "Headed to the Metaverse? Be 'The One' to Minimize Money Laundering Risk," Wilson Sonsini Advisory, July 14, 2022
Co-author with M. Casey and J. Gruenspecht, "BEIS Publishes First Annual Report Regarding the UK's National Security and Investment Act," Wilson Sonsini Alert, July 5, 2022
Co-author with A. Caiazza, J. Kaplan, J. Hartwig, J. Davey, and T. Jenkins, "No Foolish Transactions: A Few Guidelines for NFT Marketplace Participants to Mitigate Anti-Money Laundering Risks," Wilson Sonsini Advisory, May 23, 2022
Co-author with J. Davey, N. Dhir, and J. Gruenspecht, “CFIUS Rules: A Crash Course in Assessing and Navigating Risk,” Practical Guidance, March 2022
Co-author with M. Alioto, A. Caiazza, and T. Jenkins, "President Biden Signs Executive Order on Ensuring Responsible Development of Digital Assets," Wilson Sonsini Advisory, March 15, 2022
Co-author with T. Jenkins and J. Kaplan, "Is Regulation of NFTs to Combat Financial Crime on the Horizon?" Wilson Sonsini Alert, February 23, 2022
Author, “Enhanced CFIUS Rules Have Lawyers Pushing Benefits of Foreign Investment,” The National Law Journal, February 23, 2022
Co-author with M. Casey and J. Gruenspecht, "The UK’s National Security and Investment Act Now Fully in Force," Wilson Sonsini Alert, January 4, 2022
Co-author with M. Casey, J. Davey, J. Gruenspecht, and T. Jenkins, "New Rules Will Require Beneficial Ownership Reporting to Federal Regulators by U.S. and Foreign Corporations, LLCs, and Other Legal Entities," Wilson Sonsini Alert, January 4, 2022
Co-author with M. Casey, J. Davey, J. Hartwig, and T. Jenkins, "New OFAC Guidance Raises the Stakes for Crypto Industry," Wilson Sonsini Alert, October 20, 2021
Author, “Policing of foreign tech investment in the US is broken. Here’s how to fix it.” Protocol, October 4, 2021
Co-author with J. Davey and J. Kaplan, "Anonymity Becomes Passé: U.S. Government Moves to Require Ownership Information for Corporations, LLCs, and Others," Wilson Sonsini Alert, April 15, 2021
Co-author with S. Cowell and J. Gruenspecht, "Companies That Procure IT Products or Services from China, Russia, and Certain Other "Adversary" Nations May Face New National Security Questions Under the Now-Effective "ICTS" Rule," Wilson Sonsini Alert, March 25, 2021
Co-author with J. Kaplan, J.E. Krosnicki, and C. Wang, "MSB or Not MSB? That Is the Question (for Determining Applicability of Anti-Money Laundering Rules)," Wilson Sonsini Alert, January 25, 2021
Co-author, National Security Regulations 2020 Year in Review, Wilson Sonsini, December 17, 2020
Co-author with J. Kaplan, "New Anti-Money Laundering Legislation Will Create Significant Transparency Compliance Requirements for Businesses and Investors," Wilson Sonsini Alert, December 14, 2020
Co-author with J.F. Gruenspecht, J.R. Davey, and N. Dhir, "CFIUS After FIRRMA Implementation: A Crash Course in Assessing and Navigating Risk," Wilson Sonsini Alert, October 15, 2020
Co-author with J.I. Aiello LeBeau, A.E. Seymour, M.B. Mannino, and J.F. Gruenspecht, "As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat," Wilson Sonsini Alert, September 21, 2020
Co-author with A.E. Seymour and J.F. Gruenspecht, "Executive Orders on TikTok and WeChat: Ambiguity and a Few Other Takeaways," Wilson Sonsini Alert, August 7, 2020
Speaker, “The Expansion of Investment Screening: Implications for Business and Investors,” Committee on Foreign Relations, March 24, 2022
Speaker, “How to Adapt to the New National Security Review Law for Foreign Investment in US Technology Companies,” The Japan Society of Northern California and JETRO, Webinar, October 7, 2021
Speaker, "U.S. and UK Venture Investment and National Security: A Joint Discussion with CFIUS and BEIS," Wilson Sonsini Events, April 21, 2021