We counsel clients on the full range of laws governing the export and reexport of goods, technology, software, and services, and help companies navigate rapidly evolving U.S. and EU economic sanctions, including those imposed on Cuba, Iran, North Korea, Syria, Russia, Crimea, and Venezuela. We provide compliance solutions tailored to the needs of our clients, from designing compliance programs and conducting training to advising on day-to-day issues, such as export control classification analyses, obtaining licenses and opinions from regulators, and conducting time-sensitive assessments of pending transactions. We work hard to help clients and their compliance teams achieve critical compliance goals in an efficient way using practical, understandable tools that integrate seamlessly with existing business processes. We also conduct export and sanctions compliance due diligence as part of the mergers and acquisitions process, and help clients evaluate and minimize successor liability risk.
We’ve been trusted to manage hundreds of internal investigations and have brought many voluntary self-disclosures (VSDs) and formal export enforcement investigations to favorable conclusions for our clients, often without financial penalties. We are particularly experienced in analyzing large volumes of transactional, operational, and financial data in a highly systematic way to determine whether potential violations exist and to design specific and effective remedial measures to prevent future problems. This empirical approach to investigations and compliance helps companies determine their true risk exposure and whether a VSD makes sense when violations are identified. We also have decades of experience helping companies negotiate with enforcement agencies in a smart, strategic way that takes account of short- and long-term consequences for the company and individuals.
We work with companies of all sizes in all types of industries, including aerospace (with a focus on aircraft components and unmanned vehicles), financial services and banking, military and defense, software and cloud (including encryption classification and licensing), electronics and computers, vehicles and vessels of many types, optics and lasers, publishing, manufacturing (with a particular focus on materials and on oilfield and fluid handling equipment), agricultural products, telecommunications, garments and fashion, entertainment and sports, industry associations, and a wide variety of other sectors.
Our attorneys have a well-earned reputation for integrity and credibility with all of the principal U.S. sanctions and export control agencies:
- U.S. Department of Commerce’s Bureau of Industry and Security (BIS)
- U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC)
- U.S. Department of State
- U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) and counterparts at the U.S. Department of Defense (DOD)
- Nuclear Regulatory Commission (NRC)
- U.S. Department of Energy’s (DOE) National Nuclear Security Administration (NNSA)
- Enforcement agencies including Immigration and Customs Enforcement, the FBI, and the Department of Justice.