Les Carnegie advises companies, financial institutions, and private equity funds, both in the US and globally, on their outbound and inbound business transactions. He helps clients navigate US export controls, sanctions, and foreign investment reviews by CFIUS. He co-leads Latham’s Economic Sanctions & Export Controls Practice, and the CFIUS & US National Security Practice.

Mr. Carnegie advises clients on legal, policy, and enforcement issues arising under:

  • US trade and economic sanctions
  • US export controls
  • National security reviews of foreign investments in the US conducted by the Committee on Foreign Investment in the United States (CFIUS)

Mr. Carnegie draws on strong working relationships with regulators and two decades of legal experience to help clients understand legal restrictions and requirements, secure licensing, make voluntary disclosures and respond to enforcement actions, as well as maintain compliance with various US legal regimes, including:

  • National security reviews before CFIUS
  • US Treasury Department’s Office of Foreign Assets Control (OFAC)
  • US Department of State’s International Traffic in Arms Regulations (ITAR)
  • US Department of Commerce’s Export Administration Regulations (EAR), the Foreign Trade Regulations (FTR), and antiboycott regulations

He has developed particular insight on key strategic industries, including:

  • Banking and financial services
  • Energy
  • Life Sciences/Biotechnology
  • Aerospace/Defense
  • Consumer/Retail goods
  • Hospitality/Entertainment
  • Not-for-profit NGOs/Tax-exempt organizations

Mr. Carnegie frequently writes and speaks on sanctions and CFIUS topics. He is regularly recognized by Chambers USA and The Legal 500 US, and was named a Top Advisor by Foreign Investment Watch in 2020, and a Compliance MVP by Law360 in 2021. Clients describe him as “our first choice when tackling complex economic sanctions or export control compliance matters,” and “a tireless, engaging advocate and forward thinker,” whose “knowledge of US sanctions is excellent, as are his relationships with OFAC personnel.”

Mr. Carnegie organized and edited the first Foreign Direct Investment Regimes app, covering investment from several global jurisdictions.

He clerked for Judge Gerald B. Tjoflat of the US Court of Appeals for the Eleventh Circuit.

A sampling of Mr. Carnegie’s work includes representing:

Sanctions and Export Controls

  • Financial institutions regarding compliance with US sanctions in lending and capital markets transactions
  • Leading aerospace and defense companies regarding compliance with US export controls and US sanctions, including voluntary disclosures to the Treasury, Commerce, and State Departments
  • A leading energy firm, including oil exploration and production companies, as well as oil services companies regarding compliance on US export controls, US sanctions, and designing compliance programs, as well as voluntary disclosures to the Treasury and Commerce Departments
  • Leading high-technology companies, including 3-D printing companies, on compliance with US foreign trade controls
  • Several medical device and pharmaceutical companies in helping to secure government licensing for sales of humanitarian products to countries subject to US economic and trade sanctions
  • Leading not-for-profit organizations, including the International Committee for the Red Cross, CARE USA, Save the Children, and Mercy Corps, regarding compliance with US export controls and US sanctions, including securing export licensing and OFAC authorization


  • Integrated Device Technology, a leading supplier of analog mixed-signal products, including sensors, connectivity and wireless power, in its successful efforts to obtain CFIUS clearance in connection with its proposed acquisition by Japan-based Renesas Electronics, a premier supplier of advanced semiconductor solutions, in US$6.7 billion deal
  • Siemens AG, a German multinational company, in its successful effort to obtain CFIUS approval for its US$7.8 billion strategic acquisition of Dresser-Rand Group, a supplier of custom-engineered rotating equipment solutions
  • Novelis, the world leader in aluminum rolling and recycling, in its successful effort to obtain CFIUS clearance of its proposed US$2.6 billion acquisition of Aleris, a global supplier of rolled aluminum products
  • Atos SE, a global leader in digital transformation based in France, in its successful effort to obtain CFIUS clearance of its US$3.4 billion acquisition of Syntel, a US-based multinational provider of integrated technology and business services
  • Avago Technologies, a Singaporean semiconductor company, in its successful effort to obtain CFIUS approval in connection with its US$37 billion acquisition of Broadcom, a major manufacturer of telecommunications and networking equipment
  • Hytera Communications, a Chinese manufacturer and supplier of land mobile radio and digital mobile radio products, systems, and applications, in its successful effort to obtain CFIUS clearance to acquire the US business of Sepura, a UK company
  • Vision Technologies Aerospace, a maintenance and engineering group held by Singapore Technologies Engineering, in its successful effort to obtain CFIUS clearance in connection with its acquisition of MRA Systems, a unit of General Electric

Bar Qualification

  • District of Columbia


  • JD, Duke University School of Law, 1999
    with honors
  • LLM, Duke University School of Law, 1999
    with honors
  • BA, Duke University, 1996
    with honors

Languages Spoken

  • French
Carnegie, Les P.
October 5, 2021 Recognition

Compliance MVP: Les Carnegie

Washington, D.C. partner recognized for successfully completing transactions and sanctions work for a diverse set of high-profile clients.