Michael Walsh

Michael Walsh


A former chief of staff and acting General Counsel at the United States Department of Commerce, Mike advises U.S. and multinational companies and venture capital funds on all aspects of international cross-border investment, including national security, CFIUS, export controls, Department of Commerce Entity Listings, ITAR and DDTC requirements, OFAC sanctions and anti-money laundering compliance, and forced labor compliance. Mike also provides strategic counseling regarding company interactions with executive branch agencies and Congress.

Mike also represents companies in connection with Congressional investigations covering a wide range of topics including sensitive national security and supply chain issues.

Mike previously served concurrently as the chief of staff and the Chief Legal Officer at the United States Commerce Department, where he oversaw more than 600 attorneys and was responsible for all matters within the Department. He also served as the senior advisor to the Secretary of Commerce where he played a leading role in numerous issues, including those pertaining to CFIUS, export administration and enforcement, emerging technologies, and supply chain risk management. Mike also managed critical litigation in federal district and appellate courts throughout the country and coordinated the determination of Department positions on Supreme Court cases.

Mike worked with CEOs, boards of directors, and other executives regarding critical business. He interacted with foreign heads of state, ministers and other officials while representing the United States in bilateral trade talks. He worked with Cabinet members, their chiefs of staff and general counsel, and the White House on important administration policies and then executed those priorities within the Department. He also provided legal and strategic advice to the Secretary, Deputy Secretary and other senior leaders while coordinating with White House counsel and interagency lawyers on legal issues.


Representative matters

Sovereign wealth fund in connection with CFIUS issues associated with venture investments in U.S. technology, biotech, healthcare, life sciences, and entertainment companies.

European biotech company in connection with CFIUS, compliance, and regulatory issues in connection with U.S. investments.

State-owned energy company in connection CFIUS, sanctions, and compliance issues in connection with U.S. investments and acquisitions.

Asian eCommerce platform in connection with CFIUS and U.S. regulatory compliance issues.

Pro bono

Public Interest law firm on legal issues regarding Sudan and Ukraine.

Published Work

  • Walsh Jr., Michael, Co-author. (2024) “Unpacking the New Russia Sanctions and Export Controls”, Law360
  • Walsh Jr., Michael, Co-author. (2009) “Digimarc: The Final Nail in the SOX 304 Coffin”, Securities Law360
  • Walsh Jr., Michael, Co-author. (2006) “Courts Deny Plaintiffs Over Section 304 Suits”, International Financial Law Review

Speaking Engagements

  • Presenter, “Understanding the Basics of the Committee on Foreign Investment in the United States (CFIUS),” Lawline, September 2023
  • Speaker, “Geopolitics and the GC: Steering through Shifting Regulation,” Economist Impact’s General Counsel Summit US, September 2023
  • Panelist, “Complex-Conflicting-Extraterritorial: Steering Between U.S. and China Sanctions and Export Controls,” Sanctions & Export Controls Conference, May 2023
  • Speaker, “Predictions on the Intersection of U.S. Trade and National Security for Multi-National Companies,” American Conference Institute London Forum on Global Economic Sanctions, November 2021


  • “Rising Star”, Thomson Reuters, 2013–2017
  • Recognized in Securities: Shareholder Litigation, The Legal 500, 2015–2018
  • Recognized, Friend of Children (for pro bono work), Justice for Children, 2011



Washington, DC, 2003

New York, 2003

Texas, 2022


United States District Court for the District of Columbia

United States Court of Appeals for the District of Columbia

United States Court of Appeals for the District of Columbia Circuit

United States District Court for the Southern District of New York

United States District Court for the Eastern District of Michigan

United States Court of Appeals for the Second Circuit

United States Court of Federal Claims

United States Supreme Court


B.A., magna cum laude, Boston College, 1999

J.D., Columbia University School of Law, 2002

A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.