International Sanctions

Our multifaceted practice is designed to assist clients in navigating U.S. laws and issues related to international trade, investment, foreign corruption, and the national security interests of the United States. Combining the experience and knowledge of attorneys and government relations advisors, we help clients to understand their obligations, risks, and opportunities in a highly complex, high-stakes environment and rapidly increasing regulatory environment. 

Sanctions laws, regulations, and trade restrictions may be imposed by the United States government on individuals, groups, entities, and governments for diplomatic, economic, military, sports, or other reasons. Whether sanctions are based on an Executive Order by the president, laws passed by Congress, or regulations of a federal department or agency, our team brings a sophisticated understanding of the scope and manner of sanctions compliance under United States law.

Sanctions can arise from geopolitical events involving countries such as Russia, China, Ukraine, Iran, Cuba, Syria, and Venezuela and may take the form of financial sanctions, asset freezing, trade bans, or escalated tariffs that impact commercial import/export and investment activities. Because the reach of sanctions is broad, we represent clients across a host of industries — from IT to manufacturing to pharmaceuticals to AI. We advise multinational corporations, banks and financial institutions, foreign governments, foreign persons, and foreign agencies that may be impacted as sanctions are implemented, modified, and removed. 

Sanctions are being issued with unprecedented frequency and scope, often with little notice, and with severe penalties for violations. It is critical to understand the requirements and potential risks, as well as to anticipate further sanctions risks. Our team closely monitors political and legal developments to advise on complex issues to help protect your assets and your reputation. 

Our team

• Multifaceted practice addresses trade restrictions and sanctions and like regulatory issues related to international trade and investment
• Broad experience across sectors, industries, and jurisdictions 
• Deep understanding of the sanctions landscape as it rapidly changes 
• Clients include multinational corporations, banks and financial institutions, foreign governments, foreign persons, and foreign entities

Specific Agency Experience

• OFAC: Office of Foreign Assets Control (Treasury Department)
• ITAR: International Traffic in Arms Regulation (State Department)
• EAR/BIS: Export Administration Regulation (Commerce Department)
• CFIUS: Committee on Foreign Investment in U.S.
• CISA: Cybersecurity Infrastructure Security Agency (Homeland Security)
• FAR: Federal Acquisition Regulations (GAO)
• CMA: Customs Modernization Act (Customs Border Protection)
• FCPA: Foreign Corrupt Practices Act (DOJ and SEC)
• NSA: National Security Agency (Executive Branch)
• DCSA: Defense Counterintelligence and Security Agency (Defense Department)
• DOD: Defense Department
• NASA: National Aeronautics Space Administration
• NSA: National Security Agency 
• NRC: Nuclear Regulatory Commission (Energy) Department
• FCC: Federal Communications Commission (Department of Transportation)
• DOE: Department of Energy

We have experience with the  

• PATRIOT Act
• Arms Export Control Act/DDTC
• Export Administration Act/BIS
• Customs Modernization Act/CBP
• Foreign Corrupt Practices Act 
• U.S. Treasury/OFAC  
• National Security Agency (NSA) 
• Cybersecurity Infrastructure Security Agency (CISA) 
• Federal Acquisition Regulations (FAR)
• Federal Communications Commission (FCC) 
• Department of Homeland Security
• Department of Defense 
• Customs & Border Protection Agency 
• Department of Justice 
• Department of State

Following is a selected sampling of matters and is provided for informational purposes only. Past success does not indicate the likelihood of success in any future matter.

• Advised IT company in healthcare space on the retention of Cuban registered software designers
• Counseled client regarding filing a petition in Gaza versus Palestine
• Advised Russian national on an OFAC de-listing petition 
• Pursued specific license from OFAC on behalf of a blocked real estate company to permit development to continue
• Advised tax firm on permissibility of engagements with Russian clients
• Advised Russian national on potential application of U.S. sanctions
• Advised web development company on using Russian nationals to develop web 
• Advised on U.S. export control laws that affect the manufacturing, sales, and distribution of technology
• Represented persons and entities facing civil and criminal penalties in connection with violations of U.S. laws, international treaties and conventions, United Nations resolutions, acts of terrorism, boycotts, wars, and human rights violations
• Experience with the principal sanctions issuing agencies for the U.S., including the Office of Foreign Assets Control (OFAC) of the Department of Treasury, Defense Directorate of Trade Controls (DDTC) of the U.S. State Department, and the Bureau of Industry & Security (BIS) of the U.S. Department of Commerce
• Advising client on FCPA-related civil litigation