Mackenzie Zales is an attorney in Holland & Knight's Washington, D.C., office and a member of the firm's International Trade Group. Ms. Zales focuses her practice on international regulatory and compliance matters as well as a broad range of corporate issues, including foreign direct investment, industrial security, export control, sanctions and customs matters.

In the foreign direct investment space, Ms. Zales represents clients in pre-Committee on Foreign Investment in the United States (CFIUS) filing analysis, conducting due diligence to determine potential national security issues; preparing for CFIUS reviews and investigations, including assessing whether specific transaction structures create CFIUS jurisdiction; negotiating deal terms with the government and preparing filings; and advising companies regarding Foreign Ownership, Control or Influence (FOCI) mitigation/negation compliance issues.

For clients with industrial security matters to address, Ms. Zales routinely participates in the negotiation and preparation of FOCI mitigation/negation arrangements, including Special Security Agreements (SSA), proxy agreements, Security Control Agreements (SCA) and special board resolutions. Ms. Zales has performed industrial security due diligence on numerous transactions and investigated multiple regulatory violations, including FOCI mitigation, sanctions and export controls violations.

In the constantly and rapidly evolving export controls and sanctions compliance space, Ms. Zales has experience across export control regimes – including the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR) – and frequently assists clients in establishing robust export compliance policies and practices to mitigate risk and deter violations. Ms. Zales also has experience across sanctions regimes and regularly advises clients on the Russia/Ukraine crisis, including helping with issues related to sanctions compliance, obtaining Office of Foreign Assets Control (OFAC) and export licenses, and the risks of doing business in Russia.

From a customs perspective, Ms. Zales routinely assists clients with matters involving U.S. Customs and Border Protection (CBP), including related to classification, valuation, applicability of forced labor laws, and antidumping and countervailing duties (AD/CVD) and circumvention investigations.

Prior to joining Holland & Knight, Ms. Zales served as a judicial intern to the Honorable Jennifer Choe-Groves at the U.S. Court of International Trade, assisting in civil actions concerning determinations of the U.S. Department of Commerce, CBP and U.S. International Trade Commission (USITC).

In law school, Ms. Zales graduated first in her class and served as the executive editor of the University of Miami Law Review. Prior to law school, she worked as a commercial and intellectual property (IP) litigation paralegal in Holland & Knight's Boston office.

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 United Help Ukraine in its export licensing matters before the U.S. Department of Commerce for the export of bulletproof helmets and vests to Ukraine


  • University of Miami School of Law, J.D., summa cum laude
  • Dartmouth College, B.A.
Bar Admissions/Licenses
  • District of Columbia
Honors & Awards
  • Order of the Coif
  • Order of Barristers


Speaking Engagements