Tony Busch
Associate
Tony is a national security-focused international trade lawyer who advises companies how to contend with complex export controls, investment restrictions, and economic sanctions arising from an increasingly contentious global regulatory landscape.
Tony counsels clients on compliance with U.S. export controls, including the Export Administration Regulations, the International Traffic in Arms Regulations, and nuclear export controls. Tony also advises on foreign investment controls administered by the U.S. Department of the Treasury’s Office of Investment Security (OIS), including the Outbound Investment Security Program focused on semiconductors, quantum, and artificial intelligence, as well as inbound reviews conducted by the Committee on Foreign Investment in the United States (CFIUS). Tony’s experience is particularly strong in the areas of semiconductors and semiconductors manufacturing, data centers and artificial intelligence, software and encryption, aerospace and aviation, government contracting, and materials processing. Other matters Tony handles include Office of Foreign Assets Control (OFAC) economic sanctions matters, Antiboycott Regulations compliance, Foreign Trade Regulations filing procedures, and Bureau of Economic Analysis surveys.
In corporate deals, Tony identifies transactions that may trigger CFIUS Part 800 mandatory disclosure obligations, Defense Counterintelligence and Security Agency (DCSA) Foreign Ownership, Control, and Influence change condition reporting and/or mitigation requirements, and Directorate of Defense Trade Controls (DDTC) 60-day notice requirements.
Tony’s services also include interfacing on clients’ behalf with regulatory authorities such as the Bureau of Industry and Security, DDTC, CFIUS, DCSA, and Treasury’s OIS and OFAC in preparing sanctions delisting petitions, performing self-classification analysis, preparing license applications and classification requests, managing internal investigations and voluntary self-disclosures of past trade violations, drafting compliance policies, and performing international trade compliance due diligence for mergers, acquisitions, and other corporate transactions.
Tony began his practice in federal government contracting, investigations, and False Claims Act litigation and is thus particularly sensitive to the needs of clients doing business with the government or subject to government investigation. Prior to his legal career, Tony served as counterterrorism analyst.
Tony was recognized in the 2025 edition of Best Lawyers: Ones to Watch® in America in the area of Criminal Defense: White-Collar. He was also recognized as an “Associate to Watch” in the 2024 edition of Chambers USA and the 2025 edition of Chambers Global in the area of International Trade: CFIUS Experts.
- American Bar Association, International Law Section, Vice Chair (Year-In-Review) of Export Controls and Economic Sanctions Steering Committee
- District of Columbia Bar
- National Association of Muslim Lawyers
- Society for International Affairs
- Washington State Bar Association
Capabilities
Credentials
Education
Tony received his J.D. from the Washington University in St. Louis School of Law in 2016 where he was a staff editor of the Global Studies Law Review. He received his B.S. in business administration, cum laude, from the University of South Carolina, Darla Moore School of Business in 2009. While an undergraduate student, Tony studied Arabic abroad in Syria, Jordan, and Egypt through Boren and Rotary scholarships.
Admissions
- District of Columbia
- Maryland
Related Insights & News
Publications
- "Bankers Worldwide: You May Not Be Interested in Export Controls, But They Are Interested in You," Co-Author, March 2025
- “Commerce Prepares for an AI Warfare Future with Quarterly Reports of AI Modeling and Computer Cluster Plans,” Global Trade & Foreign Policy Insights, Co-Author, Sept. 12, 2024
- “Treasury Releases Text of Proposed Rule to Regulate Semiconductor Manufacturing, AI, and Quantum Investments in China,” Global Trade & Foreign Policy Insights, Co-Author, July 15, 2024
- “U.S.-China Trade Update: Recent Developments in Export Controls,” Global Trade & Foreign Policy Insights, Co-Author, June 20, 2024
- “FinCEN and BIS Expand SAR Guidance for Export Control Evasion, as General Prohibition Ten Looms Large,” Global Trade & Foreign Policy Insights, Co-Author, Nov. 8, 2023
- “CFIUS’s Annual Report Spells Trouble for Dealmakers,” Financier Worldwide, Co-author, Oct. 2023
- “U.S. Announces New Restrictions on Outbound Investments to China,” Global Trade & Foreign Policy Insights, Co-author, Aug. 30, 2023
- “CFIUS – A Growing Quagmire for Cross-Border Deals: Takeaways from CFIUS’s Annual Report for 2022,” Global Trade & Foreign Policy Insights, Co-author, Aug. 7, 2023
- “Congress Ramps Up Investigations of U.S. Venture Capital Firms Investing in Chinese Companies,” Global Trade & Foreign Policy Insights, Co-author, Jul. 28, 2023
- “China Places Export Controls on Raw Materials Used in Semiconductor Manufacturing,” Global Trade & Foreign Policy Insights, Co-author, Jul. 9, 2023
- “U.S. Sanctions and Export Controls Against Russia and FinCEN Alert,” Global Trade & Foreign Policy Insights, Co-author, May 25, 2023
- “BIS to Host Brain-Computer Interface Conference – Feb. 16 & 17, 2023,” Global Trade & Foreign Policy Insights, Co-author, Feb. 7, 2023
- “Semiconductors Trade Update: Macau, IFR Comment Period, and CHIPS Funds,” Global Trade & Foreign Policy Insights, Co-author, Jan. 26, 2023
- “BIS Imposes New Controls Targeting China’s Semiconductor and Advanced Computing Industries,” Global Trade & Foreign Policy Insights, Co-author, Oct. 13, 2022
- “Winston’s Thoughts on President Biden’s New CFIUS Executive Order,” Global Trade & Foreign Policy Insights, Co-author, Sept. 22, 2022
- “Department of Commerce Announces CHIPS for America Webinar Series,” Global Trade & Foreign Policy Insights, Co-author, Sept. 20, 2022
- “BIS Proposes Automated Peptide Synthesizers for Section 1758 Critical Technology Controls,” Global Trade & Foreign Policy Insights, Co-author, Sept. 19, 2022
- “BIS Expands Information Sharing Authorization to Members of Standards Settings Organizations, and Requests Comments,” Global Trade & Foreign Policy Insights, Co-author, Sept. 14, 2022
- “More Updates from Commerce for the Semiconductor Industry,” Global Trade & Foreign Policy Insights, Co-author, Sept. 13, 2022
- “The CHIPS Act Creates a New, CFIUS-Like, Outbound Investment Review Process for the Semiconductor Industry,” Global Trade & Foreign Policy Insights, Co-author, Aug. 22, 2022
- “President Biden Issues Executive Order Banning U.S. Imports of Russian Origin Oil, Gas, and Coal,” Global Trade, Mar. 13, 2022
- “U.S. Government Signals that Increased Sanctions and Export Controls Will Likely Follow if Russia Invades Ukraine,” Global Trade, Feb. 12, 2022
- “OFAC Sanctions Four Ukrainian Officials for Acting on Russia’s Behalf; Additional Russia Sanctions Could Follow,” Global Trade, Jan. 30, 2022
- “BIS Delays Implementation of New Cybersecurity Items Interim Final Rule,” Global Trade, Jan. 26, 2022
- “DHS Requests Comments to Inform Implementation of the Uyghur Forced Labor Prevention Act,” Global Trade, Jan. 24, 2022
- “BIS Requests Comments from Information and Communications Technology (ICT) and Semiconductor Supply Chains on Supply Chain Vulnerabilities,” Global Trade, Oct. 20, 2021
- “U.S. Government Imposes Sanctions and Issues Joint OFAC/BIS Telecommunications Fact Sheet to Support Cuban Protests,” Global Trade, Sept. 1, 2021
- “New Executive Order Authorizes Imposition of Additional Sanctions on the Government of Belarus and Certain Sectors of the Belarusian Economy,” Global Trade, Aug. 27, 2021
- “US Government Adds 4 Military-Connected Entities in Burma to Entity List and Sanctions 22 Burmese Individuals,” Global Trade, Jul. 31, 2021
- “U.S. Adds Chinese Entities to BIS Entity List and Updates Xinjiang Supply Chain Business Advisory,” Global Trade, Jul. 30, 2021
- “BIS Implements New Burma Export Controls and Adds Four Entities to the Entity List,” Global Trade, Mar. 19, 2021
- “BIS Updates Hong Kong Recordkeeping FAQs Consistent with Removal of Hong Kong from EAR Country Chart,” Global Trade, Mar. 4, 2021
- “Biden Issues Executive Order to Review Critical Supply Chains,” Global Trade, Mar. 3, 2021
- “9th Circuit Skeptical of Government Interlocutory Appeal of Unprecedented Denial of Motion to Dismiss Qui Tam Case,” 6 Pratt’s Government Contracting Law Report 117, 139, 2020
- “New DOJ Guidance for Companies Considering Voluntarily Self-Disclosing Potentially Criminal Export Control and Sanctions Violations,” The National Law Review, Dec. 27, 2019
Speaking Engagements
- 12th Annual U.S. Export Controls Year-in-Review, American Bar Association (ABA), Webinar Speaker, Feb. 16, 2023
- “Overview of New Sweeping US Sanctions and Export Controls Against Russia,” Product Liability Advisory Council (PLAC), Webinar Speaker, Mar. 10, 2022
December 18, 2024
October 25, 2024
Winston Attorneys Recognized in Best Lawyers: Ones to Watch® in America 2025
August 15, 2024