Overview

Robert A. Friedman is an experienced international trade lawyer in Holland & Knight's Washington, D.C., office. A former official with the U.S. Department of State, Mr. Friedman helps clients address a range of complex legal, regulatory and policy issues that involve international trade and investment, government regulation of cross-border transactions and compliance with U.S. laws based on foreign policy and national security. He advises businesses, entrepreneurs, investors and trade associations on matters related to economic sanctions, export controls, foreign direct investment, supply chain security, customs laws, data privacy and cybersecurity, market access, anti-corruption and national security regulations.

Mr. Friedman leverages his experience as a legal counselor and senior policy advisor to top executive branch officials to deliver practical and strategic results for clients facing a range of challenges that often entail domestic and international dimensions. His clients range from startups to Fortune 50 companies and span diverse industries, including defense, aerospace, telecommunications, finance, private equity, semiconductors, infrastructure, technology and manufacturing. He has significant experience serving as regulatory counsel in connection with mergers and acquisitions (M&A) and has obtained national security-related regulatory approvals for foreign investments from interests around the world.

Foreign Investment, National Security and Cross-Border Transactions: Mr. Friedman regularly represents clients before the Committee on Foreign Investment in the United States (CFIUS) and the Defense Counterintelligence and Security Agency (DCSA) in proceedings related to the mitigation of foreign ownership, control or influence (FOCI) under national industrial security regulations. He works with service providers and infrastructure owners in negotiating security agreements with the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector agencies – including the U.S. Department of Homeland Security (DHS), U.S. Department of Defense (DOD) and U.S. Department of Justice (DOJ) – regarding Federal Communications Commission (FCC)-regulated businesses.

Economic Sanctions, Export Controls and Trade Compliance: Mr. Friedman counsels companies regarding compliance with a broad range of cross-border legal and regulatory matters – including U.S. and multilateral economic sanctions, export controls such as International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), and foreign military sales issues – and represents them before the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), U.S. Department of Commerce's Bureau of Industry and Security (BIS), U.S. Department of State's Directorate of Defense Trade Controls (DDTC) and DOD to obtain licenses necessary to consummate investment, financial and export transactions.

Supply Chain Security, Trade Policy, Market Access, Customs and Tariffs: Mr. Friedman advises businesses on all aspects of supply chain security, including vendor and supplier due diligence, risk mitigation and requirements for government contracting. He also represents companies before the U.S. Trade Representative (USTR), U.S. Customs and Border Protection (CBP) and foreign governments in matters related to market access disputes, trade negotiations, import tariffs, and customs laws and regulations.

Prior to joining Holland & Knight, Mr. Friedman was an attorney at a leading technology and telecommunications law firm in Washington, D.C. Before entering private practice, he was a legal adviser at the U.S. Department of State, where he participated in high-stakes bilateral and multilateral negotiations in more than 20 countries across five continents and handled diverse legal issues related to treaty negotiation and interpretation, U.S. and multilateral economic sanctions, trade controls, weapons of mass destruction, outer space and cybersecurity. Mr. Friedman was the lead State Department attorney in negotiations with the Cuban government on reestablishing diplomatic relations. He served as a key legal adviser on several international arms control and nonproliferation treaties, including developing the legal architecture to address the threats posed by chemical weapons in Syria. In addition, Mr. Friedman was a senior policy advisor to the U.S. Permanent Representative to the United Nations managing participation in the White House-led interagency policymaking process on issues related to China, Russia, North Korea, Europe, cybersecurity, nonproliferation and arms control.

Mr. Friedman previously served as a nonresident Fellow at the Georgetown Center on National Security and the Law, a law clerk on the Senate Judiciary Committee staff of Sen. Patrick Leahy and an aide to then-Rep. Chris Van Hollen.

In addition to his legal practice, Mr. Friedman is an adjunct professor at Georgetown University in the School of Foreign Service's Center for Security Studies.

Representative Experience

  • Represented Blue Danube Systems during the Committee on Foreign Investment in the United States (CFIUS) clearance process in connection with its sale to NEC Corp., a Japanese technology company
  • Represented a multi-national telecommunications company based in the Philippines to obtain CFIUS clearance for its acquisition of a cloud management solutions business
  • Represented an Australian defense and aerospace company to obtain CFIUS clearance for acquisition of a satellite communications business
  • Represented a Spanish telecommunications provider in the sale of certain U.S. data center assets to a global private equity sponsor
  • Represented an Australian telecommunications company in its merger with a multi-national telecommunications company
  • Represented a Swiss private equity sponsor in its acquisition of a U.S. utility locate business
  • Represented a consortium of private equity sponsors regarding Federal Communications Commission (FCC) and Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (formerly known as Team Telecom) implications for potential acquisition of leading telecommunications infrastructure company
  • Represented a global manufacturer of aerospace platforms in the national security aspects of its potential acquisition of a U.S. company performing classified contracts for the U.S. government
  • Represented various investors in U.S. critical infrastructure and emerging technology businesses, including information and communications technology, artificial intelligence (AI) and machine learning, and data analytics
  • Represented numerous U.S. companies considering foreign investments from interests around the world, including Asia, Latin America, Europe and the Middle East

  • Counseled a leading U.S. semiconductor company on compliance with export controls in connection to its global supply chain
  • Represented a top proprietary trading company in responding to an Office of Foreign Assets Control (OFAC) subpoena
  • Advised a U.S.-based venture capital firm on national security and international trade matters, including related to portfolio company investments, compliance with U.S. sanctions and export controls, and foreign investment regulations
  • Advised a data analytics company in design and implementation of export control compliance program
  • Counseled a global telecommunications network supplier regarding compliance with economic sanctions and export control regulations restricting trade with Cuba, Iran, Russia, Venezuela and Sudan
  • Represented an international shipping company in investigation related to compliance with economic sanctions, export controls such as International Traffic in Arms Regulations (ITAR) and National Industrial Security Program Operating Manual (NISPOM) security regulations
  • Designed a trade compliance and supply chain security infrastructure for an artificial intelligence (AI) company
  • Counseled an international manufacturing company on compliance with anti-boycott regulations
  • Successfully obtained export license for shipment of computer equipment and software to Cuba for a leading environmental group
  • Assisted a U.S. company with international operations to properly classify goods, technology and software under the Export Administration Regulations (EAR)
  • Advised a leading e-commerce retailer on compliance with ITAR and contracting requirements under the Federal Acquisition Regulation (FAR) and the Security Assistance Management Manual (SAMM) related to foreign military sales and direct commercial sales programs
  • Advised a top telecommunications trade association on national security regulations related to Chinese equipment suppliers and sanctions compliance considerations in contract negotiations with a foreign vendor
  • Counseled a leading media distribution company on sanctions compliance related to provision of programming content in foreign jurisdictions
  • Obtained favorable U.S. Department of the State and OFAC guidance for an international non-governmental organization's proposed grant program for entities in Cuba

  • Developed supply chain security framework for a global business with extensive ties to Chinese counterparties
  • Counseled multiple technology and telecommunications companies regarding supply chain security considerations for doing business with the U.S. government
  • Advised multiple foreign companies on U.S. market access considerations, including trade policy, customs laws and regulations, and data privacy
  • Represented a national appliance distribution company in responding to trade tariffs imposed under Section 301 of the Trade Act of 1974, including engagement with U.S. Trade Representative (USTR), and successfully obtaining product exclusions
  • Represented an international premium foods company in tariff classification protest before U.S. Customs and Border Protection (CBP)
  • Counseled a global communications infrastructure company on trade policy, foreign investment and national security regulations related to international operations in Australia
  • Advised an industry-leading satellite communications company on nontariff trade barriers imposed by India that significantly impacted U.S. operators
  • Represented a global submarine cable supplier in public international law, treaty and comparative law matters, including those involving the law of the sea
  • Counseled multiple foreign companies in telecommunications and private equity industries on investment survey filings mandated by the U.S. Department of Commerce's Bureau of Economic Analysis (BEA)

Credentials

Education
  • Georgetown University Law Center, J.D., cum laude
  • Johns Hopkins University, M.A., Government, with honors
  • Emory University, B.A., Political Science
Bar Admissions/Licenses
  • District of Columbia
Court Admissions
  • U.S. Supreme Court
  • U.S. Court of Appeals for the Fourth Circuit
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. District Court for the District of Columbia
  • U.S. District Court for the District of Maryland
Memberships
  • Council on Foreign Relations, Term Member
  • Anti-Defamation League, Regional Board Member, Washington, D.C.,

Publications

Speaking Engagements

News