Publications

• “Lessons From SAP's Multiagency Illegal Export Penalty,” Law360, May 2021 (co-author)
• “The Devil's in the Details,” Petroleum Economist, September 2017 (co-author)
• "Resellers Must Heighten Their Sanctions Due Diligence," Law360, March 2016 (co-author)
• "New U.S. Policy on Armed Drone Exports Steals the Spotlight – but Changes are Coming for Commercial UAS Too,” The Metropolitan Corporate Counsel, March 2015 (co-author)

Representative Experience: Economic Sanctions*

• Conducted an internal investigation of a global technology company’s compliance with OFAC’s internet communications general licenses, resulting in a VSD process before OFAC
• Counseled U.S. and non-U.S. companies regarding the wind down and divestment of transactions and operations following the re-imposition of sanctions on Iran, Russia, and Venezuela
• Obtained specific licenses from OFAC on behalf of clients, including authorization related to the provision of online services to embargoed countries by a U.S. technology company
• Conducted a global internal investigation of compliance with U.S. sanctions regulations for a U.S.-based financial services company, resulting in a successful VSD process before OFAC
• Assisted a global travel company with a VSD process before OFAC regarding alleged violations of sanctions regulations regarding travel to Cuba
• Advised software, payments, FinTech, cloud computing, and other companies on identifying potentially sanctioned users on their platforms
• Counseled a technology company on compliance with OFAC general licenses regarding services incident to communications over the internet
• Conducted an investigation of alleged diversion of a manufacturing company’s products to Iran by customers and other third parties
• Advised a global internet advocacy non-profit on compliance with sanctions regulations
• Obtained required licenses from OFAC to ‘unblock’ a global manufacturing company and its assets following the imposition of U.S. Russia-related sanctions
• Assisted a money transfer company with the assessment of its OFAC compliance program and the roll out of enhanced policies and procedures related to SDN screening, personal remittance general licenses, reporting, and other sanctions issues
• Designed, assisted with the implementation of, and audited technology companies’ sanctioned party screening programs
• Conducted an internal investigation of an e-commerce company’s compliance with OFAC and BIS regulations and managed the resulting VSD process
• Advised a major sports league on compliance with U.S. sanctions issues, including those related to the informational materials exemptions and related general licenses
• Counseled non-U.S. companies in a variety of industries, including in the technology, metals and mining, shipbuilding, materials, manufacturing, and finance sectors, on compliance with secondary sanctions and the extraterritorial application of U.S. trade compliance rules
• Conducted global risk assessments and on-going quality assurance monitoring for an international financial services company
• Counseled a non-U.S. telecommunications company on compliance with U.S. sanctions, including the various telecommunications and related general licenses to OFAC’s regulations
• Conducted an internal investigation and resolved the related enforcement matter for a chemical company regarding alleged diversion of products to Iran
• Assisted a HealthTech company in responding to an administrative subpoena from OFAC regarding access of services from embargoed countries
• Counseled a global intellectual property services company on compliance with OFAC’s regulations, including the various general licenses applicable to patents and trademarks
• Advised companies on U.S. sectoral sanctions affecting the Russian financial and energy industries and targeted sanctions on Venezuela
• Conducted sanctions and trade compliance risk assessments during M&A due diligence processes for clients in a variety of industries, including the financial, energy, manufacturing, and technology sectors
• Assisted U.S. financial institutions with responses to administrative subpoenas from OFAC and other U.S. government agencies and with related enforcement matters

*Includes experience from a previous firm

Representative Experience: Export Controls*

• Obtained export control licenses and authorizations regarding the export of telecommunications and internet communications items to sanctioned and restricted countries
• Advised technology and software companies on U.S. export control rules applicable to cloud computing platforms
• Advised U.S. and non-U.S. technology companies on compliance with U.S. end use and end user export control restrictions, including those related to the Entity List, semiconductors, and advanced computing
• Conducted an internal investigation and successful VSD process regarding violations of U.S. export control regulations on behalf of a global telecommunications and technology company before BIS
• Advised technology companies on compliance with export controls related to encryption, quantum computing, semiconductors, artificial intelligence, and open source development
• Advised U.S. technology companies on the hiring of foreign nationals from export-controlled destinations
• Advised big data, artificial intelligence, and information and network security companies on product classification, including obtaining formal export control classification rulings
• Conducted a global internal investigation, VSD process, and follow-up audits for a materials company regarding violations of the U.S. export control regulations administered by BIS
• Advised manufacturers, exporters, and global distributors of U.S.-origin encryption equipment, software, and technology on compliance with International Traffic in Arms Regulations (ITAR) and EAR classification, licensing, and reporting requirements
• Designed and conducted a 45-facility audit of a global manufacturing company for compliance with U.S. export control and sanctions rules, among other global auditing projects
• Conducted an internal investigation for an optics manufacturer resulting in a successful VSD process involving DDTC
• Obtained required export licenses for manufacturers of unmanned aerial vehicles from U.S. export control agencies
• Conducted a global export control classification project for a manufacturer of capital equipment that involved the classification of millions of line items under the U.S. EAR, ITAR, and nuclear regulations
• Obtained favorable jurisdictional and classification rulings from NNSA and NRC regarding non-U.S. nuclear power plant projects

*Includes experience from a previous firm