DAANISH HAMID is a partner in Rimon’s Washington DC office. He has had over 20 years experience representing clients on Global Investigations, International Trade, and National Security matters. His practice covers the Committee on Foreign Investment in the United States (CFIUS), the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws, anti-money laundering/anti-terrorist financing matters, mail and wire fraud statutes, and OFAC sanctions and embargoes. He is also experienced in supply chain due diligence reviews under the Uyghur Forced Labor Prevention Act (UFLPA). In addition to handling these regulatory matters, Daanish represents clients on a variety of joint venture, teaming, sales representative, distribution, reseller, and other commercial transactions.
Daanish regularly advises c-level executives and company boards on international investigations and related government disclosure strategies. He supports clients with designing, implementing, and auditing corporate compliance programs. Companies call upon Daanish to provide international compliance trainings and perform regulatory due diligence in the context of M&A transactions, investment deals, joint ventures, and business partner relationships.
He has led numerous investigations, compliance matters, and commercial transactions involving Asia, Africa, the Middle East, and Latin America. Daanish represents clients before the Department of the Treasury (OIS, FinCEN, and OFAC), the Department of Commerce (BIS), the Department of Justice (Fraud Section), the Department of Homeland Security, the Securities and Exchange Commission (Division of Enforcement), the Department of Defense, and other U.S. government agencies.
He serves as outside counsel to emerging businesses, prominent public companies, PE/VC firms, and international financial institutions, including multi-lateral development banks. His clients tend to be involved with the technology (AI, big data, ecommerce, edtech and fintech), financial services, defense, aerospace, manufacturing, supply chain/logistics, and energy sectors.
Daanish is the author of the FCPA chapter of the Third Edition of Corruption and Misuse of Public Office, a leading treatise published by Oxford University Press. He previously served as a board member of TRACE International, a prominent anti-corruption organization. Daanish has a law degree with honors from the University of Oxford and a Juris Doctor from the George Washington University Law School, where he was a member of the International Law Review.
REPRESENTATIVE CFIUS MATTERS
- Successfully filed a voluntary notice with CFIUS on behalf of a large publicly-traded diagnostic testing company in relation to its $2 billion acquisition by a European company.
- Successfully filed a voluntary notice with CFIUS on behalf of a high-net-worth businessman from Asia who committed to invest over $100 million in a US investment fund that will finance a variety of US technology and other portfolio companies.
- Successfully represented a large Japanese conglomerate in obtaining CFIUS approval with respect to its two-stage minority investment in a US technology company.
- Successfully represented an Asian company on a mandatory declaration filed with CFIUS pertaining to its minority investment (consisting of non-public information rights) in a US wireless technology company.
- Successfully represented a European public limited liability company on two CFIUS filings with respect to its strategic investment in a U.S.-based supply chain software provider.
- Successfully represented an Asia-based business conglomerate on a CFIUS filing pertaining to its $60 million acquisition of a US water and wastewater equipment company that supplies the US military.
- Advised a US semiconductor company on CFIUS regulatory compliance in relation to certain unit purchase agreements involving prospective Chinese investors, joint venture partners, and licensees.
- Counseled a variety of European, Middle East and Asian CVC’s and investment firms (including Chinese state-affiliated entities) on structuring their funds and financing transactions in a manner to mitigate against CFIUS filing risks in relation to US portfolio investments.
- Advised several US technology, automotive, defense and healthcare companies on the CFIUS aspects of their investment and M&A deals with foreign investors and acquirers.
REPRESENTATIVE FCPA/AML COMPLIANCE MATTERS
- Counseled a major defense and aerospace company in performing hundreds of FCPA due diligence reviews on its commission sales representatives, fixed- fee consultants, resellers and supply chain vendors.
- Established a comprehensive FCPA/global anti-corruption compliance program for a multinational agribusiness company.
- Advised an IoT technology company on potential anti-money laundering implications associated with Chinese investors.
- Represented a South Asian sovereign government on U.S., UK, Canadian, and Australian anti-corruption concerns in relation to an arbitration dispute.
- Counseled a variety of venture capital firms on appropriate FCPA/anti-money laundering due diligence protocols applicable to foreign investors (including sovereign wealth funds) and portfolio companies.
- Guided a financial services company on FCPA, anti-money laundering, sanctions, and business ethics due diligence in the context of M&A transactions.
- Performed global anti-corruption risk and compliance audits and assessments for a construction company.
REPRESENTATIVE SANCTIONS MATTERS
- Advised a prominent, publicly traded defense and aerospace company on sanctions compliance regarding several third-party vendors and representatives.
- Counseled a multinational semiconductor company on the implications associated with Huawei entities appearing on the US Department of Commerce’s Entity List.
- Supported a US energy company with respect to sanctions matters impacting an EPC contract pertaining to the establishment of a methanol gas plant.
- Guided a multi-party consortium consisting of various Japanese business conglomerates on the application of US sanctions and export controls to their chemical engineering joint venture in Venezuela.
- Counseled a US government-affiliated financial institution on the impact a sanctioned counterparty would have on the closing conditions of a multi-million-dollar back-to-back loan guarantee.
- Guided a European water technology company on US withdrawal from the Joint Comprehensive Plan of Action and the application of restored sanctions on its projects with Iranian-state-affiliated entities.
- Advised an M&A buy-side party with respect to Iranian, Ukrainian, Syrian, and Cuban sanctions violations committed by a target technology company.
REPRESENTATIVE CORPORATE INVESTIGATION MATTERS
- Led an internal investigation for a publicly-traded software client into anti-corruption and anti-competition matters in the Middle East.
- Conducted an investigation into anti-corruption, anti-kickback, and conflicts-of-interest concerns for a technology company with respect to a European referral partner.
- Managed multiple FCPA investigations for a Fortune 500 specialty materials company in China, Korea, Japan, and certain other Asian countries.
- Led internal investigations for a prominent gas and energy company falsely accused of corruption by certain political interests in Latin America.
- Advised a US air cargo company in an ICC arbitration relating to the termination of its Southeast Asian agent due to corruption allegations.
- Represented a mining equipment company with respect to certain agent transactions in Nigeria and other African countries.
- Investigated a construction company’s operations in India in relation to fraud, kickback, vendor padding, and government bribery allegations.
- Conducted an investigation into alleged improper payments and the use of unauthorized subcontractors by a Chinese distributor of a geo-mapping company.
- Led internal investigations for a telecommunications company in relation to government bribery and tax dispute matters in South Asia.
- Conducted FCPA and fraud investigations for a multimedia company in relation to a joint venture in Latin America.
- Supported an investigation/joint defense of various business partners in relation to a government privatization matter in Eastern Europe subject to scrutiny and eventual settlement by the US Department of Justice.
- Advised a US financial services company on a fraud investigation triggered by a third party that misappropriated the client’s trademark and misrepresented to various other parties that it is an authorized representative of the client.
REPRESENTATIVE M&A/INVESTMENT MATTERS
- Counseled Parsec, a high-performance remote desktop and streaming technology company, on its $320 million sale to Unity (NYSE: U).
- Supported Electrocomponents plc on its US$145 million acquisition of Synovos, Inc, an independent provider of maintenance, repair, and operations (MRO) supply chain management services.
- Advised FullStory, a leader in digital experience intelligence (DXI), on its oversubscribed US$103 million Series D financing round with participation from Permira’s growth fund, Kleiner Perkins, GV (formerly Google Ventures), Stripes, Dell Technologies Capital, Salesforce Ventures and Glynn Capital.
- Supported a US technology company on its $52 million asset purchase of an HR platform software and workforce management hardware business.
- Advised a data-driven private equity firm on corporate and regulatory matters related to the close of its inaugural US$500 million fund which provides founder-led, software-as-a-service (SaaS) companies with the active partnership, proprietary technology and expansion capital needed to scale their businesses.
- Counseled AEye, Inc, a global leader in adaptive, high-performance LiDAR solutions, on its transition from a Series A investment to a SPAC closing and public listing on the NASDAQ. This occurred via a business combination with CF Finance Acquisition Corp. III, a special purpose acquisition company that valued AEye pre-closing at over US$1.5 billion.
- Advised Solis LLC and Parasol Renewable Energy LLC on their $155 million sale of renewable energy company Clenera to Enlight Renewable Energy Ltd., a global renewables independent power producer (IPP) and developer.
- Represented a Japanese corporate VC on numerous strategic and passive minority investments in autonomous technology and robotics portfolio companies.
- Represented a US industrial component manufacturer that acquired three different Korean suppliers to major vehicle manufacturers.
- Presenter, “How Dealmakers Need to Think About CFIUS”, Live Webinar co-hosted with Judy Deng (Moderator), October 11, 2022
- Panelist, “Roundtable & Open Forum on the Ukraine/Russia Conflict”, hosted by the International Trade Council, March 2022
- Moderator, “Navigating a successful legal career path in the financial services industry,” South Asian Bar Association Webinar consisting of panelists from PayPal, Robinhood, and HSBC, 2021.
- Panelist, “International Trade and Cross-Border Transactions in the Era of Trade War,” Asia Business Conference, Harvard Business School, 2020.
- Presenter, “Emerging Cross-Sector Topics: Privacy, Security and Operating Across Borders,” InvestED Conference – Finding Opportunity in the Global Education Industry, 2019.
- Presenter, “CFIUS: A Practical Guide for CVCs,” Global Corporate Venturing & Innovation Summit, 2019.
- Presenter, “Does Law Enforcement Have You in its Sights? – Essential Knowledge on the Latest Developments in Anti-Money Laundering and Sanctions Affecting Lawyers,” International Bar Association Annual Conference, 2019.
- Panelist, “Trade Wars, Tariffs, FIRRMA, and CFIUS: Your Top Questions Answered,” Rock Center for Corporate Governance, Stanford Law School/Silicon Valley Directors’ Exchange, 2018.
- Presenter, “The Latest Schemes to Hide Corruption: How to Restructure Your Risk and AML Strategies in Light of New Tactics,” ACI’s 9th Global Forum on Anti-Corruption Compliance in High Risk Markets, 2018.
- Presenter, “Vetting and On Boarding New Partners: Risk-Based Due Diligence Strategies for Evaluating New Intermediaries, Brokers, Distributors, Suppliers and Agents,” American Conference Institute’s 28th National Conference on the Foreign Corrupt Practices Act, 2018.
- Presenter, “Good Corporate Governance & Anti-Terror Financing Enforcement: How to Navigate the Post-9/11 Environment and Advise Nonprofit Organizations,” NAML Annual Conference, 2018.
- Presenter, “International Contracting: Anti-Corruption Compliance and Local Law Considerations,” National Contract Management Association, 2016.
- Presenter, “International Anti-Corruption Compliance – Concerns for Private Equity Investors,” 20th Annual Private Equity CFO Conference, San Francisco, 2016.
- Presenter, “Strategies for Effective Auditing and Due Diligence of Third Parties in China: Special Focus on Beneficial Ownership,” ACI’s 8th Global Forum on Anti-Corruption Compliance in High Risk Markets, 2015.
- Presenter, “Anti-Corruption/FCPA Compliance and Investigations – How to Put Your Best Food Forward,” Bloomberg BNA Speaker Series, 2015.
- Presenter, “Overcoming Foreign Corrupt Practices Act Compliance Challenges in China and India,” American Conference Institute’s 16th National Foreign Corrupt Practices Act Conference, New York, 2015.
- Presenter, “FCPA and Economic Sanctions: Leveraging Internal Screenings and Healthcare Compliance Resources to Reduce Penalty Risks,” ACI’s 10th Advanced Forum on FCPA and Anti-Corruption for the Life Sciences Industry, 2014.
- Presenter, “FCPA Enforcement and Compliance Strategies – Overview,” Practicing Law Institute’s International Briefing Series, 2014.
- FCPA enforcement: primed to re-emerge under Biden?, By Financier Worldwide, March 2023
- CFIUS – Upping the Ante, By Asian Legal Business Thomson Reuters, Sarah Wong, November 18, 2022
- The Foreign Corrupt Practices Act – An Executive Summary, Client Alert, November 16, 2022
- CFIUS Enforcement and Penalty Guidelines Just Issued, Client Alert, October 20, 2022
- CFIUS National Security Reviews Cover Certain Real Estate Transactions, Client Alert, co-authored with Ivan Komaritsky, October 2, 2022
- CFIUS: A Practice Overview for Dealmakers, Client Alert, June 21, 2022
- The new Anti-Money Laundering Act of 2020: A potential game-changer for enforcement and compliance, Client Advisory, 11 Jan 2021.
- Voluntary CFIUS Filings May Limit Uncertain Outcomes, Law360, 25 June 2021.
- Q&A with Danish Hamid on Recent Committee on Foreign Investment in the United States (CFIUS) Developments, The National Law Review, 5 November 2020.
- New CFIUS regulations change mandatory filing requirements and increase the importance of US export controls, Client Advisory, 30 September 2020.
- World Bank sanctions in Africa: a formidable compliance concern, Client Advisory, 11 August 2020.
- CFIUS encourages public to provide tips and referrals, Client Advisory, 24 June 2020.
- CFIUS filing fees effective as of May 1, 2020: What you need to know, Client Advisory, 5 May 2020.
- New regulations reinforce CFIUS’s expanded role with respect to foreign investments in the United States, Client Advisory, 16 January 2020.
- United States – Global bribery offenses guide, Client Advisory in association with Transparency International, 4 December 2019.
- Must Read by M&A Personnel – Key Points on the Committee on Foreign Investment in the United States (CFIUS) and FIRRMA, Nikkei, Japan, 29 November 2018.
- CFIUS Chapter of the American Bar Association’s Aerospace and Defense Industries Year in Review, 2019.
- FCPA Chapter of the Third Edition of Corruption and Misuse of Public Office, a leading treatise published by Oxford University Press, 2017.
News, Events, & Insights
- Investigations & Compliance Report (ICR): Foreign Corrupt Practices Act - When Can Concerns Arise
Insights October 30, 2023
- Financier Worldwide Magazine: FCPA enforcement: primed to re-emerge under Biden?
Insights June 20, 2023
- Legis Webinar: Corporate Integrity: Mitigating Against Corruption and Money Laundering Risk
Events June 7, 2023
- Asian Legal Business: CFIUS - Upping the Ante
Insights November 18, 2022
- The Foreign Corrupt Practices Act - An Executive Summary
Insights November 16, 2022
- CFIUS Enforcement and Penalty Guidelines Just Issued
International Blog October 20, 2022