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Janine Slade

Drawing upon her experience at the U.S. Department of Homeland Security (DHS), Janine Slade advises clients on the U.S. national security review process administered by the Committee on Foreign Investment in the United States (CFIUS) and related reviews conducted by the interagency working group known as “Team Telecom.”

Ms. Slade served in a number of roles during her nearly 10-year tenure at DHS, including as Deputy Director, Foreign Investment Risk Management, and as an Attorney Advisor in the Office of the General Counsel. She advised Department leadership and component offices on matters relating to CFIUS and Team Telecom, assisted with compliance oversight of CFIUS national security agreements, and negotiated national security risk mitigation measures with corporate counsel for companies under review and investigation by CFIUS and Team Telecom. She also provided technical assistance to congressional staff and the CFIUS chair on Foreign Investment Risk Reduction & Modernization Act (FIRRMA) statutory reform and accompanying regulatory reform efforts.

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Updated August 8, 2023.  Originally posted May 1, 2023.

Last week, comment deadlines were announced for a Federal Communications Commission (“FCC”) Order and Notice of Proposed Rulemaking (“NPRM”) that could have significant compliance implications for all holders of international Section 214 authority (i.e., authorization to provide telecommunications services from points in the U.S. to points abroad).  The rule changes on which the FCC seeks comment are far-reaching and, if adopted as written, could result in significant future compliance burdens, both for entities holding international Section 214 authority, as well as the parties holding ownership interests in these entities.  Comments on these rule changes are due Thursday, August 31, with reply comments due October 2.Continue Reading Comments Due August 31 on FCC’s Proposal to Step Up Review of Foreign Ownership in Telecom Carriers and Establish Cybersecurity Requirements

Yesterday, the Federal Communications Commission (“FCC”) unanimously adopted an order formalizing the referral and review process associated with “Team Telecom”—the group of national security and law enforcement agencies responsible for assessing foreign investment in U.S. telecommunications, submarine cable licensees, and broadcast licensees. The order adopts rules and procedures that will govern what has long been an informal process at the agency, both in connection with the issuance of such licenses and with respect to transfers of control.

The FCC’s action is consistent with the agency’s increased focus on, and involvement in, questions around national security and foreign investment in the telecommunications and media sectors. This attention to national security at the FCC is likely to continue regardless of the outcome of the election in November, given that both Republicans and Democrats at the agency have supported the agency’s heightened role in national security matters under its jurisdiction.Continue Reading FCC Formalizes Foreign Investment Reviews; More National Security Actions Likely to Follow