Joseph Pauloski (’13): CFIUS Staff Chair and Director, Office of Investment Review & Investigation

“My work at CFIUS touches every industry, all types of analysis, and countries around the world. I can encounter all sorts of topics in one day.”
-Joseph Pauloski (’13)

Please note that this article contains Joseph’s personal views and does not represent the views of the U.S. Government.

Joseph Pauloski (’13) has spent years working on a Committee that reviews foreign direct investment in the United States for national security risk, and if it’s identified, ensures it’s appropriately addressed. As of this year, he leads it, and he has likely reviewed hundreds of billions in foreign direct investment on behalf of the U.S. Government.

His role at the Department of the Treasury and as Staff Chairperson on the Committee on Foreign Investment in the U.S. (CFIUS) has allowed him to make a significant impact on the security of our country, including prohibiting a Chinese-backed cryptocurrency mining facility from operating near a strategic U.S. Air Force base.

Here, he shares his story, from pushing a mail cart at the Pentagon to joining the elite Senior Executive Service within the U.S. Government.

Starting out at the Pentagon

Joseph was still a student at IWP when he was referred by fellow IWPers to a contract at the Pentagon. He was given a choice of two positions: working on Department of Defense directives and traditional paperwork or pushing the mail cart. He chose pushing the mail cart.

“I learned that a lot of people turned down the mail cart role,” said Joseph. “I figured it would let me meet more people.”

The role involved visiting every office in the Department of Acquisition, Technology and Logistics in the Pentagon. On his first day at work, Joseph met a Colonel who advised him to wear a suit every day and be courteous to everyone he met, and that it would lead to more options. In less than a year, Joseph was invited to work in the front office of one of the most senior officials in the Pentagon – the Principal Deputy Undersecretary for Acquisitions, Technology, and Logistics in the Office of the Secretary of Defense.

What started as a role managing his boss’ calendar and basic administrative tasks grew over time. Joseph was given opportunities to help with memos, collaborate with senior military staff, and more. He remembers: “It gave me gigantic visibility into everything that fell into the purview of the office.”

Joseph continued to meet people, including contractors, staff, generals, and the equivalent of generals. He was exposed to work on the industrial base and supply chains.

He later ended up in a different part of the Department working on international armaments cooperation. From there, he consulted on supply chains and foreign investment at Deloitte, worked at the Treasury, and served at the White House.

During his detail to the White House Office of Science and Technology Policy, Joseph worked on the Executive Order on Ensuring Robust Consideration of Evolving National Security Risks by the Committee on Foreign Investment in the United States. This order described what CFIUS already did but served as a guide to the government and general public about the administration’s priorities within CFIUS. This guide was important because most CFIUS work is conducted with strict confidentiality.

Reviewing foreign investments to ensure U.S. national security

Today, Joseph is a member of the Senior Executive Service, a group of leaders within the U.S. Government who serve directly below top Presidential employees and who are equivalent to a general officer or flag officer rank within the U.S. Armed Forces.

Joseph has two significant roles: he is the Director for the Department of the Treasury’s Office of Investment Review and Investigation, as well as the Staff Chairperson for CFIUS – a role delegated to him by the Secretary of the Treasury.

As Director of his office, he oversees over 40 staff members. He and his team review and investigate transactions that involve foreign acquisitions of U.S. businesses and determine if there are national security risks. This work involves coordination with other members of CFIUS – the Department of Defense, Department of Energy, Department of Homeland Security, Department of Commerce, Department of State, Department of Justice, the White House Office of Science and Technology Policy, and the U.S. Trade Representative.

If CFIUS determines that there are no unresolved national security risks, then parties will be notified that they’ve received “safe harbor” specific to that transaction. If there is a risk, CFIUS members write a risk-based analysis and determine how to address the risk, which can include negotiating a national security agreement with the parties. This process involves coordinating across Treasury, the Committee, and engaging with law firms and the companies themselves. If the risk cannot be mitigated, CFIUS may consider other options, including referring the matter to the President who has the authority to prohibit it.

As the CFIUS Staff Chair, Joseph manages the interagency aspect of this process and serves as the primary authority for certain actions under its regulations. A consensus must be reached during the review of each transaction.

“It involves a lot of coordination,” said Joseph. “We meet every week on every case, sometimes even more so. We engage with each other almost every day.”

Mitigating the threat from China

Joseph has managed the processing of likely hundreds of cases filed with CFIUS throughout his career. Information filed with CFIUS is strictly confidential, even just the names, but when the President takes action and announces it, they can become known, including one high-profile case that became public this year.

Thanks to the work of Joseph and his team, President Biden issued an order blocking MineOne, a Chinese-affiliated company, from owning property within a mile of Francis E. Warren Air Force Base in Wyoming.

Warren AFB is a strategic missile base that houses Minuteman III intercontinental ballistic missiles. MineOne was using its nearby property as a crypto mining facility. The case came to the attention of CFIUS through a public tip, and Joseph and his team played a critical role in the entire process, including its ultimate referral to the President. “The proximity of the foreign-owned cryptocurrency mining facility to a strategic missile base and key element of America’s nuclear triad, and the presence of specialized and foreign-sourced equipment potentially capable of facilitating surveillance and espionage activities, presented a significant national security risk that led to CFIUS’s referral to the president,” read the release.

The company was required to remove its equipment and divest its ownership of this property.

For his work on this case, Secretary Janet Yellen presented Joseph with the Secretary’s Certificate of Appreciation in July 2024.

The IWP education at work

Joseph has found that his IWP education has helped him in navigating nuance:

“There are a number of classes at IWP that go through all the various views of topics. The small, intimate nature of IWP allows for free-flowing conversation to go through all these views. This experience is helpful in my work at CFIUS, which spans multiple types of analysis, legal issues, financial issues, national security, a variety of industries, different countries, different structures, and different types of transactions and business agreements. My education has helped me navigate situations where it is not obvious what the right analytic answer is.”

At IWP, Joseph’s smallest class had four students, and his largest class had a little over 20 students. “You can’t hide in the back!” he said.

Conversations in class also helped Joseph in navigating interpersonal relationships. “A lot of my work involves interpersonal engagement and negotiations. It’s a lot easier to convince someone of your position or find agreement if you have a good relationship with them.”

His IWP studies also helped him at the very beginning of his career. With Prof. John Tsagronis, he wrote national security memos for class, which were very similar to the memos he saw when he started out at the Pentagon. It gave him a foundation for the framing and preparation of memos. Now he oversees their creation at Treasury.

To current IWP students who are starting their careers, he shares this advice: “Don’t be afraid to ask questions and put yourself out there! Genuinely consider the positives and negatives of every potential role. Get your foot in the door, excel, and go from there.”