Carolyn (Carrie) Schroll

Special Counsel

Phone number
(202) 342-8635

Carrie Schroll’s practice focuses on counseling, internal investigations and enforcement matters, and implementation of compliance programs, related to economic sanctions, export controls, and the U.S. Foreign Corrupt Practices Act (FCPA). Carrie also advises clients on anti-boycott restrictions, anti-money laundering regulations, and reviews and investigations before the Committee on Foreign Investment in the United States (CFIUS).

She advises a diverse range of clients in various sectors, including the technology, chemicals, manufacturing, transportation, and consumer goods sector, on international trade compliance and navigating the complex intersecting regulatory regimes. She also advises clients, including strategics and private equity sponsors, on due diligence in connection with corporate transactions and fundraising. She counsels clients in conducting internal investigations related to potential noncompliance with economic sanctions, export controls, and anti-corruption laws, preparing related voluntary self-disclosures or subpoena responses, and advocating for clients in front of the relevant regulator.

Carrie routinely develops sanctions, import, export, and anti-corruption compliance programs for clients across multiple industries and works closely with clients to implement and enhance compliance programs.

Conducted internal investigation and submitted voluntary self-disclosure related to violations of the International Traffic in Arms Regulations on behalf of a global technology company.

Assisted global manufacturing company with internal investigation and voluntary self-disclosure to Census regarding the Foreign Trade Regulations.

Counseled global chemicals and fibers producer on a trade compliance risk assessment and years-long implementation of enhanced sanctions and export controls compliance policies, procedures, and training.

Conducted a trade compliance risk assessment for a global food and beverage provider and assisted in implementing a new compliance program.

Ongoing counseling for an association client related to compliance with anti-corruption laws, including developing policies, redrafting agreements, and providing training.

Assisted clients in the renewable energy sector with navigating the CFIUS review process in connection with proposed transactions.

Prepared and submitted licensing requests to governmental agencies, including BIS and OFAC, and advocated with the agencies on the clients’ behalf.

Advised diverse clients in developing sanctions and export compliance programs, including written policies, restricted-party screening procedures, training, and auditing.

Assisted multiple software clients in internal investigations and submission of voluntary self-disclosures to the Departments of Commerce and Treasury related to compliance with export controls and sanctions.

Advised a chemical producer on the export controls classification of products and an internal investigation into historical compliance with the Export Administration Regulations.

Counseled clients across multiple industries on compliance with enhanced US, EU, and UK sanctions and export controls related to Russia and Belarus.

Advised hardware and software developers on the implications of export controls on semi-conductors and supercomputing technology related to China.

Conducted trade due diligence reviews for mergers and acquisitions for large private equity sponsors.