Export Controls and Sanctions Compliance
Export Controls and Sanctions Compliance
Understanding and complying with the legal requirements involved in exporting products, software, services and funds across borders is critical to reducing the risks involved in international business, and when violations occur, it’s important to have a trusted, tested advisor to help navigate next steps.

Our export controls and economic sanctions attorneys offer clients one-stop, full-service export controls and economic sanctions counseling.  We advise clients on the full range of laws governing the export and reexport of goods, technology, software and services, and help them navigate the rapidly changing U.S. and EU economic sanctions against Russia, Crimea, Syria, Iran and Cuba, among other locations.

Our team designs and implements tailored compliance systems and comprehensive technology-based data management plans, and provides on-site and web-based training to technical and sales personnel in the nuts and bolts of export compliance―all with the goal of minimizing the risk of violations. We provide counsel on day-to-day issues, including helping clients obtain classifications and export licenses for products, software and technology.  We’re relied on for time-sensitive export issues and specific and complex questions regarding potential export violations.  We’ve been trusted to manage hundreds of internal investigations and have brought many voluntary self-disclosures and formal export enforcement investigations to favorable conclusions for clients.  We also conduct due diligence export compliance reviews as part of the mergers and acquisitions process, and help clients evaluate and minimize successor liability risk.

We work with all types of industries, including aerospace (with a focus on aircraft components and unmanned vehicles), military and defense, software and cloud (including encryption classification and licensing), electronics and computers, vessels, optics and lasers, publishing, manufacturing (with a focus on materials and on oilfield and fluid handling equipment), agricultural products, telecommunications, garments and fashion, financial services and banking, entertainment and sports, industry associations, and a wide variety of other sectors.

Our attorneys have a keen understanding of the nuances associated with self-reporting and enforcement, and 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 (DOE)

  • Enforcement agencies including Immigration and Customs Enforcement, the FBI, and the Department of Justice.
  • Counseled a large publishing house regarding implementation of a denied party screening process, dealing with “hits” against denied party screening lists, and understanding the scope of the informational materials provisions of the OFAC regulations.

  • Counseled a professional sports league with sanctions counseling, licensing issues, and the use of exceptions related to their activities and broadcasts.

  • Assisted international travel service companies with assistance related to changing U.S. sanctions programs and licensing requirements, particularly in Cuba.

  • Assisted a large financial institution with a major internal investigation and voluntary self-disclosure related to international and domestic transactions with potentially denied parties and countries.

  • Assisted trustees and financial institutions with issues related to financial transactions, stock transfers, dividend payments, interest payments and related activities under U.S. sanctions.

  • Assisted numerous U.S. manufacturers and their foreign subsidiaries in establishing policies and procedures for exporting products legally to Iran, under new OFAC General License H.

  • Assisted numerous U.S. petrochemical equipment companies with proposed transactions under the new OFAC and Commerce Department, BIS sanctions on Russia.

  • Assisted a large manufacturer of fluid handling equipment in achieving a successful multi-million dollar settlement related to a voluntary self-disclosure to OFAC of numerous violations, avoiding larger penalties.

  • Provided counseling, compliance program development, licensing assistance, and training to multiple unmanned vehicle manufacturers and the largest unmanned vehicle association.

  • Provided licensing assistance, counseling and training to an international joint venture manufacturing significant components of military aircraft.

  • Develop technology assistance agreements and other licensing vehicles under the ITAR for multiple manufacturing and technology companies.

  • Assist companies responding to administrative and criminal subpoenas from BIS, ICE, OFAC, and the Department of Justice.

  • Provided export compliance training, counseling and licensing assistance to a high technology company with over 20,000 monthly export shipments of electronic products, software and related technology, including a high percentage of exports containing encryption.

  • Assisted the European subsidiaries of a large U.S. company with over 24 foreign affiliates in the review of all products for export and reexport license requirements, and related commercial and military export controls in the U.K., Italy, Netherlands, Spain, France, Switzerland, Germany, Denmark, Belgium and Ireland.

  • Advised an international manufacturing company with $4 billion in annual revenue concerning numerous potential export control violations, analysis of potential voluntary disclosure, document retention policies and processes, improvements to their compliance system and related issues. Coordinated 35 U.S. and foreign site visits to conduct export compliance reviews. Conducted in-person advanced export compliance training seminars for compliance managers.

  • Assisted a large multinational telecommunications company in connection with the protection in Europe of encryption software against unauthorized disclosure in violation of U.S. and EU export control laws.

  • Prepared and implemented a customized compliance system at a large e-logistics provider with international operations.

  • Drafted content for Commerce and State Department export compliance modules for a major e-learning training provider.

  • Assisted with preparation, implementation and training for a customized compliance system at a major electronics supply company.

  • Drafted an EU Export Control Compliance Manual for a large company with products having military, dual-use and nuclear applications; and advise the company on supplementary export control obligations arising in individual European countries.

  • Assisted a U.S. company that purchased a company on the Commerce Denied Parties list, having that acquired entity’s denial order terminated early.

  • Acted as advisor to U.S. pump and valve industry associations regarding export control issues.

  • Advised a Fortune 50 retailer regarding export compliance issues.  Draft and design web-based compliance training programs.

  • Prepared a voluntary self-disclosure (VSD) involving 200+ ITAR-controlled exports of technical data, resolved with a warning letter.

  • Conducted an internal compliance audit and prepared a VSD for a radar system and laser guidance system component manufacturer. The matter involved more than 80 reported violations and was resolved with a warning letter. Provided remedial training and process improvements.

  • Prepared a VSD and implemented an export compliance system for a Patriot Air Defense System missile component exporter.

  • Conducted a compliance audit, prepared a VSD, and designed and implemented a compliance system for a missile propulsion and explosives manufacturer.

  • Prepared a VSD under ITAR and implemented compliance system improvements for a major valve manufacturer and supplier to the U.S. Navy.

  • Prepared an export compliance system for a major submarine component manufacturer.

  • Provided export compliance advice to numerous defense industry clients, including: an aircraft fighter jet component exporter, a missile nose cone manufacturer, leading composite materials defense products manufacturers and a start-up defense services/training company.

  • Provided ITAR classification advice to a battlefield fuel cells manufacturer.

  • Provided commodity jurisdiction advice to a military and commercial vehicle component manufacturer with $5 billion in annual revenue.

  • Provided commodity jurisdiction and compliance advice for a military/intelligence electronics manufacturer.

  • Provided counsel in relation to CFIUS matters, including the successful 2015 acquisition of a U.S. company manufacturing classified missile components and numerous other controlled aerospace products. Successfully designed a Defense Security Service agreement for that company to continue to operate in accordance with requirements for the control of classified data.
 
 

Overview

Understanding and complying with the legal requirements involved in exporting products, software, services and funds across borders is critical to reducing the risks involved in international business, and when violations occur, it’s important to have a trusted, tested advisor to help navigate next steps.

Our export controls and economic sanctions attorneys offer clients one-stop, full-service export controls and economic sanctions counseling.  We advise clients on the full range of laws governing the export and reexport of goods, technology, software and services, and help them navigate the rapidly changing U.S. and EU economic sanctions against Russia, Crimea, Syria, Iran and Cuba, among other locations.

Our team designs and implements tailored compliance systems and comprehensive technology-based data management plans, and provides on-site and web-based training to technical and sales personnel in the nuts and bolts of export compliance―all with the goal of minimizing the risk of violations. We provide counsel on day-to-day issues, including helping clients obtain classifications and export licenses for products, software and technology.  We’re relied on for time-sensitive export issues and specific and complex questions regarding potential export violations.  We’ve been trusted to manage hundreds of internal investigations and have brought many voluntary self-disclosures and formal export enforcement investigations to favorable conclusions for clients.  We also conduct due diligence export compliance reviews as part of the mergers and acquisitions process, and help clients evaluate and minimize successor liability risk.

We work with all types of industries, including aerospace (with a focus on aircraft components and unmanned vehicles), military and defense, software and cloud (including encryption classification and licensing), electronics and computers, vessels, optics and lasers, publishing, manufacturing (with a focus on materials and on oilfield and fluid handling equipment), agricultural products, telecommunications, garments and fashion, financial services and banking, entertainment and sports, industry associations, and a wide variety of other sectors.

Our attorneys have a keen understanding of the nuances associated with self-reporting and enforcement, and 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 (DOE)

  • Enforcement agencies including Immigration and Customs Enforcement, the FBI, and the Department of Justice.

Experience

  • Counseled a large publishing house regarding implementation of a denied party screening process, dealing with “hits” against denied party screening lists, and understanding the scope of the informational materials provisions of the OFAC regulations.

  • Counseled a professional sports league with sanctions counseling, licensing issues, and the use of exceptions related to their activities and broadcasts.

  • Assisted international travel service companies with assistance related to changing U.S. sanctions programs and licensing requirements, particularly in Cuba.

  • Assisted a large financial institution with a major internal investigation and voluntary self-disclosure related to international and domestic transactions with potentially denied parties and countries.

  • Assisted trustees and financial institutions with issues related to financial transactions, stock transfers, dividend payments, interest payments and related activities under U.S. sanctions.

  • Assisted numerous U.S. manufacturers and their foreign subsidiaries in establishing policies and procedures for exporting products legally to Iran, under new OFAC General License H.

  • Assisted numerous U.S. petrochemical equipment companies with proposed transactions under the new OFAC and Commerce Department, BIS sanctions on Russia.

  • Assisted a large manufacturer of fluid handling equipment in achieving a successful multi-million dollar settlement related to a voluntary self-disclosure to OFAC of numerous violations, avoiding larger penalties.

  • Provided counseling, compliance program development, licensing assistance, and training to multiple unmanned vehicle manufacturers and the largest unmanned vehicle association.

  • Provided licensing assistance, counseling and training to an international joint venture manufacturing significant components of military aircraft.

  • Develop technology assistance agreements and other licensing vehicles under the ITAR for multiple manufacturing and technology companies.

  • Assist companies responding to administrative and criminal subpoenas from BIS, ICE, OFAC, and the Department of Justice.

  • Provided export compliance training, counseling and licensing assistance to a high technology company with over 20,000 monthly export shipments of electronic products, software and related technology, including a high percentage of exports containing encryption.

  • Assisted the European subsidiaries of a large U.S. company with over 24 foreign affiliates in the review of all products for export and reexport license requirements, and related commercial and military export controls in the U.K., Italy, Netherlands, Spain, France, Switzerland, Germany, Denmark, Belgium and Ireland.

  • Advised an international manufacturing company with $4 billion in annual revenue concerning numerous potential export control violations, analysis of potential voluntary disclosure, document retention policies and processes, improvements to their compliance system and related issues. Coordinated 35 U.S. and foreign site visits to conduct export compliance reviews. Conducted in-person advanced export compliance training seminars for compliance managers.

  • Assisted a large multinational telecommunications company in connection with the protection in Europe of encryption software against unauthorized disclosure in violation of U.S. and EU export control laws.

  • Prepared and implemented a customized compliance system at a large e-logistics provider with international operations.

  • Drafted content for Commerce and State Department export compliance modules for a major e-learning training provider.

  • Assisted with preparation, implementation and training for a customized compliance system at a major electronics supply company.

  • Drafted an EU Export Control Compliance Manual for a large company with products having military, dual-use and nuclear applications; and advise the company on supplementary export control obligations arising in individual European countries.

  • Assisted a U.S. company that purchased a company on the Commerce Denied Parties list, having that acquired entity’s denial order terminated early.

  • Acted as advisor to U.S. pump and valve industry associations regarding export control issues.

  • Advised a Fortune 50 retailer regarding export compliance issues.  Draft and design web-based compliance training programs.

  • Prepared a voluntary self-disclosure (VSD) involving 200+ ITAR-controlled exports of technical data, resolved with a warning letter.

  • Conducted an internal compliance audit and prepared a VSD for a radar system and laser guidance system component manufacturer. The matter involved more than 80 reported violations and was resolved with a warning letter. Provided remedial training and process improvements.

  • Prepared a VSD and implemented an export compliance system for a Patriot Air Defense System missile component exporter.

  • Conducted a compliance audit, prepared a VSD, and designed and implemented a compliance system for a missile propulsion and explosives manufacturer.

  • Prepared a VSD under ITAR and implemented compliance system improvements for a major valve manufacturer and supplier to the U.S. Navy.

  • Prepared an export compliance system for a major submarine component manufacturer.

  • Provided export compliance advice to numerous defense industry clients, including: an aircraft fighter jet component exporter, a missile nose cone manufacturer, leading composite materials defense products manufacturers and a start-up defense services/training company.

  • Provided ITAR classification advice to a battlefield fuel cells manufacturer.

  • Provided commodity jurisdiction advice to a military and commercial vehicle component manufacturer with $5 billion in annual revenue.

  • Provided commodity jurisdiction and compliance advice for a military/intelligence electronics manufacturer.

  • Provided counsel in relation to CFIUS matters, including the successful 2015 acquisition of a U.S. company manufacturing classified missile components and numerous other controlled aerospace products. Successfully designed a Defense Security Service agreement for that company to continue to operate in accordance with requirements for the control of classified data.
Partner
Email (202) 342-8841(202) 342-8841
Eric McClafferty chairs the firm’s International Trade group.  He has substantial experience in counseling, compliance programs, internal investigations and enforcement matters related ...
Partner
Email (202) 342-8488(202) 342-8488
With a practice at the intersection of law, economics, domestic politics and international relations, John Herrmann represents clients before all U.S. trade agencies.  He counsels U.S. produc...
Partner
Email (202) 342-8530(202) 342-8530
Larry Lasoff has nearly three decades of experience helping a broad spectrum of clients navigate the complex regulatory hurdles of international trade and customs.  He is also involved in man...
Partner
Email (202) 342-8835(202) 342-8835
Alan Luberda practices in the areas of international trade, customs, and export controls law and regulation.  He counsels and represents businesses – from large multinationals to family...
Partner
Email (212) 808-7982(212) 808-7982
Deepak Nambiar is a partner in the firm's New York office.  He focuses his practice on a wide range of corporate and general commercial matters, with special emphasis on technology licens...
Senior International Trade/Government Relations Advisor
Email (202) 342-8563(202) 342-8563
Bill Reinsch is a senior international trade/government relations advisor in the firm’s Washington, D.C. office. Bill brings over four decades of experience in designing and enforcing intern...
Partner
Email (312) 857-7083(312) 857-7083
Julian Solotorovsky chairs the firm’s White Collar Crime and Investigations practice group.  His practice is focused on litigation, including white collar crime, internal investigations...
Partner
Email +(32)(2) 899-2931+(32)(2) 899-2931
Laura van der Meer is dedicated to assisting her clients in understanding and navigating complex international and European policy and legislative processes to better protect and advance their int...
Special Counsel
Email +32.2.899.2942+32.2.899.2942
Frédéric Dopagne is special counsel in the firm’s Brussels office. His practice focuses on advising and representing sovereign States, international organizations and their respective organs...
Senior Associate
Email (202) 342-8516(202) 342-8516
Brooke Ringel advises on international trade.  She assists companies, associations and coalitions across a wide range of industries in navigating, effectively utilizing and leveraging U.S. tra...
Associate
Email (202) 342-8622(202) 342-8622
Robert Slack is an associate in the firm’s Washington, D.C. office. His practice focuses on export controls, economic sanctions, and anti-corruption matters.  Robert advises clients in ...
Associate
Email (202) 342-8528(202) 342-8528
Scott Wise is an associate in the firm’s Washington, D.C. office. His practice focuses on export controls and economic sanctions matters. Prior to joining the firm, Scott was an associate in...
Analyst
Email (202) 945-6661(202) 945-6661
Greg Rohling is a trade analyst with Georgetown Economic Service (GES).  He has experience conducting comprehensive export audits for clients in connection with voluntary self-disclosures and...