Justin T. Huff
PEOPLE

Justin T. Huff

Partner
huff.justin@dorsey.com

Overview

JUSTIN FOCUSES ON HELPING CLIENTS NAVIGATE REVIEWS BY THE COMMITTEE ON FOREIGN INVESTMENT IN THE UNITED STATES (“CFIUS”) AN INTERAGENCY COMMITTEE THAT EVALUATES CROSS-BORDER MERGERS, ACQUISITIONS, AND CERTAIN INVESTMENTS TRANSACTIONS FOR POTENTIAL NATIONAL SECURITY CONCERNS.

Justin Huff is a Partner in the firm’s Washington, D.C. and Salt Lake City offices. Prior to entering private practice, Justin served as a Deputy Director in the United States Department of the Treasury office responsible for chairing CFIUS. Justin led the review of hundreds of CFIUS filings and conducted in-depth national security analyses on transactions across a wide range of industries, including biotech, agriculture, technology, telecommunication, real estate, and energy. Justin also engaged in extensive inter-agency communications and consensus building with the eight other agencies on the CFIUS committee. Prior to his Treasury role, Justin held senior positions with the United States Department of Agriculture and the Office of the Director of National Intelligence.

After serving in the federal government for over a decade, Justin entered the private law practice and has advised domestic and international clients on CFIUS regulations and their impact on hundreds of high-profile cross-border corporate transactions. He is recognized as a leading attorney for CFIUS by Chambers Global and by Chambers USA.
 

Education & Admissions

George Mason University (J.D., 2005)

Utah State University (B.S., Economics, 2001), magna cum laude

Admissions

  • District of Columbia
  • Utah

Experience

Representative Matters

Buy Side Representations

  • Represented a Saudi Arabian Government entity in review and investigation of its investment in a mining company with a U.S. business with significant sales ultimately destined for the Defense Department.
  • Represented a German buyer in connection with its acquisition of a U.S. oil and gas technology company.
  • Represented a European technology company in connection with multiple investments in U.S. companies to determine the applicability of CFIUS’s mandatory notification requirements.
  • Represented several China-based companies in transaction-based CFIUS analysis for their investments in the United States.
  • Represented Singaporean company in CFIUS filings in connection with its acquisition of multiple U.S. businesses.
  • Advised Chinese AI company regarding potential implications of CFIUS regulations on its business.
  • Advised multiple companies in connection with their acquisition of real estate in the United States in connection with greenfield investments.
  • Represented a Chinese company in connection with its acquisition of a U.S. chemical company.
  • Represented a European company in connection with its acquisition of a U.S. software company.

Sell Side Representations

  • Negotiated a first of its kind mitigation agreement on behalf of a U.S. energy storage company in connection with investment by a Chinese company.
  • Represented a U.S. semiconductor manufacturer in connection with the sale to a Chinese investment company.
  • Represented a European founder in his sale of his U.S. aerospace business and negotiated a complex mitigation agreement with the U.S. Department of Defense.
  • Provided counsel to multiple U.S. companies that received requests for information (RFI) from CFIUS related to “non-notified” investments.
  • Represented U.S. designer and producer of 4G and 5G networking equipment in its sale to a conglomerate from the United Arab Emirates.
  • Represented a Chinese private equity fund in connection with the sale of a U.S. portfolio company after outreach from CFIUS.
  • Represented a series of venture capital funds and their growth stage portfolio companies in their transaction-based CFIUS analysis and post-closing CFIUS work.

News & Resources

Articles

Justice Proposes to Restrict U.S. Personal Data to Countries of Concern, Including China
Commerce Department Proposes Reporting Requirements for Certain Artificial Intelligence Models and Computing Clusters
Biden Administration Finalizes Section 301 Tariff Increases on Some Chinese Goods, Announces Proposed Rules to Limit De minimis Exemption Imports
Commerce Department Adopts Sweeping Changes in U.S. Export Controls
Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters
New NPRM Augments Executive Order 14105 Affecting Outbound U.S. Investment into China
President Biden Will Keep Section 301 Tariffs and Increase Duty Rates Sharply on Certain Chinese-Origin Goods
U.S. Piles on Array of New Sanctions Against Russian Military-Industrial and Financial Sectors
Biden Administration Adds Sanctions Against Foreign Financial Institutions Supporting Russia’s Military-Industrial Base
Fundamental Research & National Security: Recent Developments & New Issues
Executive Order 14105 on Outbound Investment in China and Proposed Rule
Outbound Investment Screening Becomes a Reality
Foreign-Owned U.S. Companies Must Soon Respond to Federal Survey
United States Imposes New 200% Tariffs on Russian Aluminum, Further Expands Sanctions on Russia, and Warns of New Third Country Sanctions
United States Continues Expansion of Export Control Sanctions on Chinese Companies
Congress, President Align on Powerful New U.S. Intellectual Property Protection Law
Key Takeaways From President Biden’s Executive Order 14083 on Ensuring Robust Consideration of Evolving National Security Risks by the Committee on Foreign Investment in the United States (“CFIUS”)
CFIUS Annual Report - A Banner Year for Filings and Inquiries to Parties of Non-Notified Transactions
United States Bans Russian-Affiliated Ships from Entering Any U.S. Port
U.S. Government Sanctions Sberbank and Alfa Bank, Prohibits All New Investments in Russia, Imposes New Export Restrictions against Russian Civil Aviation & Ends PNTR Status for Russia and Belarus
U.S. National Security Issues in Cross-Border Food, Beverage & Agribusiness Deals
Biden Administration Revises and Expands Restrictions on U.S. Person Investment in Chinese Companies and Releases New List of “Chinese Military Companies” Under 2021 NDAA Section 1260H
U.S. Reimposes Economic Sanctions On Military Regime in Burma
U.S. Department of Commerce Sanctions Seven Chinese Supercomputer Firms
New U.S. Government Review Process Effective March 22 for Information Communications Technology and Services from China, Russia and Other “Foreign Adversaries”

News & Press Mentions

Chambers USA 2024 Recognizes Dorsey Lawyers and Practices
Chambers Global 2024 Recognizes Dorsey Partners and Practices
Chambers USA 2023 Recognizes 23 Dorsey Lawyers and Four Practices in Salt Lake City
Chambers USA 2023 Recognizes Dorsey Lawyers and Practices
Chambers Global Honors Dorsey U.S.-China Practice Attorneys
Chambers Global 2023 Recognizes Dorsey Partners and Practices
Chambers USA 2022 Recognizes Dorsey Lawyers and Practices
Dorsey Partner Justin Huff Comments on CFIUS Under Biden Administration
Former Senior CFIUS Official Justin Huff Joins Dorsey

Industries & Practices

Government Contracts Counseling & Litigation
Government Solutions & Investigations
Healthcare Transactions & Regulations
Higher Education & Academic Research Institutions
  • Banking & Financial Institutions
  • China
  • Development & Infrastructure
  • Emerging Companies
  • Energy & Natural Resources
  • Europe
  • Food, Beverage & Agribusiness
  • Government Contracts Counseling & Litigation
  • Government Solutions & Investigations
  • Healthcare & Life Sciences
  • Healthcare Transactions & Regulations
  • Higher Education & Academic Research Institutions
  • Intellectual Property
  • International Trade
  • Mergers & Acquisitions
  • National Security Law
  • Private Equity
  • Real Estate & Land Use
  • Technology
  • Technology Commerce

Accolades

Chambers USA 2024 Dorsey LogoChambers Global 2023Chambers USA 2023Chambers 2022

  • Recognized by Chambers Global (International Trade: CFIUS Experts), 2023
  • Named one of “America’s Leading Business Lawyers” by Chambers USA (International Trade: CFIUS Experts), 2022-2024
  • Secretary's Honor Award, Department of the Treasury (2018)
  • National Intelligence Certificate of Distinction Award (2013)
Justin T. Huff