Scott C. Jansen

Counsel

Washington, D.C.
T +1.202.861.1705
F +1.202.861.1783

Overview

Scott Jansen’s experiences across multiple U.S. federal agencies and as a congressional aide, most recently as Mitigation Compliance Counsel at the Department of Defense (DoD) Committee on Foreign Investment in the U.S. (CFIUS) Office and as General Counsel/Legal Advisor at the U.S. Air Force JAG Corps, have positioned him well to guide clients through CFIUS cases, as well as complex export controls, sanctions and embargo matters.

Scott’s early experience in export controls was honed at DoD in the context of CFIUS cases. He currently advises companies across all types of export control matters (including jurisdiction and classification determinations and regulatory filings) and companies facing increased sanctions risks across their global business operations. He also advises on CFIUS matters.

As DoD Mitigation Compliance Counsel, Scott interacted with the staff and attorneys of the Departments of the Treasury, Justice, Energy and Homeland Security and other CFIUS Committee members on a regular basis as he addressed CFIUS compliance and agreement negotiation matters and concerns. As an Air Force JAG, Scott handled multiple assignments in criminal trial and appellate litigation, and provided legal counsel on procurement, international law, military operations law and ethics law as part of a worldwide practice. His military career included tours in Iraq, Afghanistan, Liberia, Guantanamo Bay, Germany and Belgium, providing him with an international viewpoint and the ability to discern the global ramifications of diverse legal matters. During his last year on active duty, Scott was detailed to the Department of Justice Criminal Division, Fraud Section, where he assisted prosecutors in the FCPA, Securities Fraud and Health Care Fraud Units on a wide range of criminal prosecutions.

Scott holds an LL.M. in National Security Law from Georgetown University Law Center, and expects to obtain an LL.M. in Government Procurement Law from George Washington University Law School in 2024.

Select Experience

  • Represents defense industrial base company with an active DTCC consent agreement requiring export control classifications of numerous products, as well as proactive engagement with the compliance officer and DTCC.
  • Advises both U.S. and non-U.S. clients in numerous industries on the impact of the evolving U.S. sanctions response to the invasion of Ukraine.
  • Advised cryptocurrency investors on CFIUS filing requirements.
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Experience

  • Represents defense industrial base company with an active DTCC consent agreement requiring export control classifications of numerous products, as well as proactive engagement with the compliance officer and DTCC.
  • Advises both U.S. and non-U.S. clients in numerous industries on the impact of the evolving U.S. sanctions response to the invasion of Ukraine.
  • Advised cryptocurrency investors on CFIUS filing requirements.
  • Advised a U.S. company and a state university on facility clearances and related personnel clearances.
  • Extensive experience in negotiating and drafting CFIUS national security agreements, including amendments to existing agreements.
  • Held a leadership role in DoD CFIUS Compliance and Monitoring Team, overseeing the real-time compliance of over 110 signed CFIUS agreements.
  • Acted as Lead Compliance Counsel for over 40 CFIUS agreements, with duties ranging from conducting site visits, audit reviews, engaging with outside and inside counsel, senior management officials and third-party monitors and auditors and approving and enforcing CFIUS security policies (including cybersecurity, data security and export control requirements).
  • Had frequent interaction with attorneys from the Departments of the Treasury, Justice, Energy and Homeland Security CFIUS on CFIUS matters across the life of CFIUS agreements (original approval, amendments and waivers, termination) and on-going compliance efforts and concerns.
  • Served as lead and second chair on over 20 criminal trials, 25 other contested hearings (including classified hearings) and over 50 criminal appellate appeals, including five oral arguments.

Recognitions and Memberships

Memberships

  • American Bar Association
    • International Export Controls and Economic Sanctions Committee
    • National Security Committee
    • International Anti-Corruption Committee (Steering Committee 2017 to 2018)
  • Society for International Affairs
  • The Bar Association of the District of Columbia
  • Washington State Bar Association

Prior Positions

  • U.S. Department of Defense: CFIUS Mitigation Compliance Counsel (2018 to 2022)
  • U.S. Department of Justice, Criminal Division, Fraud Section: Detailed from U.S. Air Force JAG Corps (2017 to 2018)
  • U.S. Air Force JAG Corps, Worldwide Practice: General Counsel/Legal Advisor, Prosecutor, Criminal Defense, Criminal Appeals (2004 to 2018)
  • U.S. Attorney's Office, Eastern District of Washington: Law Clerk (2002 to 2004)
  • Rep. George R. Nethercutt, Jr.: Capitol Hill Legislative Assistant (1996 to 2001)

Military Service

  • U.S. Air Force JAG Corps: Major, retired (2004 to 2018)

Admissions

  • U.S. Court of Appeals for the Armed Forces
  • U.S. Air Force Court of Criminal Appeals
  • U.S. Supreme Court
  • District of Columbia
  • Washington

Education

  • LL.M. Candidate, Government Procurement Law, George Washington University Law School, 2024 (anticipated)
  • LL.M., National Security Law, Georgetown University Law Center, 2018; Journal of National Securiy Law and Policy, LL.M. Editor
  • J.D., Gonzaga University School of Law, 2004, cum laude; Gonzaga Law Review, Articles Editor; Across Borders International Law Journal, Associate Editor
  • B.A., Biola University, 1996, cum laude