Adam Vaccaro

• Served as CFIUS (Committee on Foreign Investment in the United States) Coordinator for the Department of Commerce, responsible for leading policy implementation and national security reviews of transactions subject to CFIUS jurisdiction
• Managed the ITA (International Trade Administration) OIS (Office of Investment Security) team and overall mission as the lead policy entity for Commerce and coordinated internal Commerce stakeholders to ensure all Commerce equities were considered in CFIUS national security reviews of certain incoming investments to U.S. businesses
• Negotiated CFIUS mitigation agreements with parties undergoing CFIUS national security reviews to address identified national security risks
• Led policy research, analysis, and coordination for CFIUS and other national security-focused investment issues
• Senior career-level policy briefer for the Secretary, Deputy Secretary, and Under Secretary for International Trade, members of Congress, and other senior-level officials concerning CFIUS and other national security policy considerations involving investment flows and impact of national security considerations on other Commerce programs
• Senior career-level Commerce official responsible for creating and implementing the Outbound Investment Security Program that features outbound investment prohibitions or required notifications of investments in certain technology sectors (semiconductors, quantum computing, and artificial intelligence) and reviewed these provisions for potential changes pursuant to the America First Trade and Investment Policy Memoranda
• Lead Commerce career level policy representative for the implementation of regulations pursuant to the Foreign Investment Risk Review Modernization Act of 2018 and ongoing CFIUS regulatory efforts
• Led a consulting team supporting the Department of Defense’s (DOD) participation as an agency member of CFIUS to identify, assess, and analyze the national security implications of inward investments for potential national security concerns
• Responsible for budgeting, recruiting, client engagement, contract management, and substantive policy input to inform the DOD’s position on transactions under CFIUS review, analysis of relevant defense procurement issues involving CFIUS, and larger trade and investment issues that impact U.S. national security
• Analyzed threats from proliferation finance networks and the use of U.S. sanctions authorities to address them and briefed senior-level Treasury officials on these issues
• Drafted and provided input for analytic products for senior-level Treasury officials concerning financial sanctions and combating weapons of mass destruction (WMD) proliferation, money-laundering, financial sanctions, counter terrorism finance policies, and other illicit finance concerns
• Supported senior-level Treasury officials on diplomatic outreach regarding U.S. sanctions authorities including engagement with foreign governments and other stakeholders on U.S. sanctions implementation and compliance requirements
• Supported multilateral and interagency diplomacy efforts as an action officer for Iran policy, responsible for coordination of policy efforts to ensure implementation of U.S. autonomous measures and UN Security Council Resolutions for senior-level State Department officials

In his consulting roles, Adam has:

• Led teams providing strategic advice and other professional services to global financial services clients, analyzing clients’ financial crimes risk exposure and developed implementation plans to enhance Office of Foreign Assets Control (OFAC) sanctions compliance programs

Prior to joining DLA Piper, Adam served as:

• CFIUS Coordinator/Director for the Office of Investment Security (OIS), Department of Commerce, International Trade Administration (ITA), Washington, DC, March 2019 – November 2025
• Senior Program Manager for consulting company for the Department of Defense (DOD), Arlington, Virginia, July 2017 – November 2018
• Manager – Federal Practice, Strategy Service Line, at a multinational professional services firm, Washington, DC, October 2015 – June 2017
• Manager – Financial Crimes Compliance Practice, at a multinational professional services firm, Washington, DC, September 2014 – October 2015
• Positions in the Office of Terrorism and Financial Intelligence, United States Department of the Treasury, Washington, DC, November 2011 – August 2014
• Foreign Affairs Officer, United States Department of State, Washington, DC, September 2007 – November 2011