Share and Download Sanctions and Export Controls
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Advisory and Compliance
- Sanctions and export controls risk assessments
- Compliance program design, testing, and implementation
- EAR and ITAR jurisdiction, classification, and licensing
- Deemed exports and technology controls
- Supply‑chain, distributor, and counterparty screening
- Board-level and workforce training
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Investigations and Voluntary Disclosures
- Internal investigations and compliance lookbacks
- Exposure assessments and remediation planning
- Voluntary self disclosures to OFAC, BIS, DDTC, DOJ, and other regulators
- Regulator engagement and settlement strategy
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Enforcement and Defense
- OFAC, BIS, DDTC and other agencies’ civil enforcement actions in the US
- DOJ criminal proceedings
- Executive, board level, and other individual representation
- Cross border coordination with non-US authorities
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Industry Experience
- Artificial Intelligence
- Big Tech
- Biotech/Life Sciences
- Blockchain and Cryptocurrency
- Defense and Aerospace
- E-commerce
- Energy
- Financial Services
- Government Services
- Healthcare
- Information Technology
- Manufacturing
- Medical Devices
- Media and Entertainment
- Pharmaceuticals
- Securities
- Social Media
Trump Administration Charts Ambitious Path Toward US Critical Mineral Dominance
Client AlertUK Financial Sanctions Compliance and Enforcement Update
BlogKey Contacts
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Ambassador Robert M. Kimmitt
Senior International Counsel
[email protected] +1 202 663 6250+1 202 663 6250
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Matthew G. Olsen
Partner
Chair, Defense, National Security and Government Contracts Practice
[email protected] +1 202 663 6359+1 202 663 6359
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Representative Matters
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Advisory and Compliance
- Advised a number of industrial multinationals with remaining operations in Russia on navigating successive sanctions packages in the US, EU and UK as they apply to relations with local subsidiaries and on obtaining necessary licenses and authorizations.
- Advised life sciences multinational clients on navigating complex, multi-jurisdictional sanctions and export control rules on humanitarian trade in Russia, China and other global markets.
- Advised numerous clients in various industries (IT, media, manufacturing and energy) on compliance with US and EU sanctions and export control restrictions applicable to winding down operations in Russia after February 2022. Assisted with developing internal compliance plans to execute wind-downs, engaging with OFAC on Russian countermeasures and protecting local employees and IP rights.
- Advised one of the world’s largest central securities depositories on US sanctions compliance, including engagement with OFAC to obtain guidance and authorizations for complex financial services involving blocked assets and dealings with Directive 4 entities. Assisted with developing defenses under US sanctions law against litigation claims based on Russian court orders and countermeasures.
- Provided comprehensive trade compliance advice (ITAR, EAR, OFAC and FTR) to a US-based global manufacturer of motion control products, including developing and enhancing internal policies, delivering training, conducting risk assessments and compliance reviews and making voluntary self-disclosures to regulators when issues arose. This work also includes diligence and compliance advice for M&A transactions.
- Advised one of the world’s largest social media companies on compliance obligations under international sanctions laws, including risks posed by platform monetization features vulnerable to abuse. Advised on regulatory expectations for sanctions due diligence and helped develop an effective compliance program. This work posed novel challenges in implementing controls on a platform operating at significant scale and exemplifies the firm’s strong cross-border capabilities.
- Advised a digital communications and technology multinational on US, EU and UK trade compliance and sanctions measures, including licensing, compliance requirements by transaction type and risk assessments. After the client decided to terminate operations in Russia, advised on divesting its Russian business in an orderly, sanctions-compliant manner, including steps to minimize retaliation risk to employees and remaining assets.
- Advised clients involved at various levels (wholesale, retail and global laboratories) of the international diamond trade on compliance with Kimberley Process requirements and US and EU import bans on Russian diamonds and jewelry.
- Represented a global manufacturer of video and monitor display products in BIS licensing matters involving reexports of US software used in offshore design and production activities and across its global supply chain. This work included reviewing the client’s export control procedures and analyzing the impact of recent BIS foreign direct product rules on licensing requirements.
- Conducted an ITAR internal investigation for a defense contractor with regard to international transactions involving sensitive defense technology.
- Advised a defense sector advanced technology business on application of the “defense services” rules regarding cybersecurity activities.
- Conducted diligence for a cross-jurisdictional M&A transaction on economic sanctions and export control risk screening and provided advice on applicable restrictions related to legacy clients.
- Conducted diligence for an M&A transaction involving application of ITAR and EAR to an advanced materials company and provided day-to-day follow-on advice on export control requirements post-close.
- Conducted a sensitive ITAR internal investigation for an advanced technology company.
- Conducted an ITAR internal investigation for an advanced aeronautics company.
- Advised various clients on China’s anti-sanctions and blocking statutes, as well as informal sanctions.
- Advised a university about compliance with US antiboycott laws, including with respect to campus activities in support of BDS initiatives.
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Enforcement
- Represented Fokker Services in a BIS, OFAC and DOJ sanctions violation investigation and prosecution, resulting in the successful negotiation of a global resolution including a Deferred Prosecution Agreement with DOJ.
- Represented US fund managers in DOJ and OFAC sanctions violation investigations.
- Represented a US investment management firm in OFAC, DOJ and SEC investigations concerning possible enforcement actions against international transfers of funds, financial services and investment activity alleged to involve the property interests of a prominent Russian oligarch designated as a blocked person.
- Conducted an extensive internal investigation for a holding company concerning assets and operation of a trust to confirm they were not the property interest of a Russian party sanctioned under US and EU law. Prepared a memorandum of findings and supported engagement with financial institutions and investment funds to show there was no basis under applicable US or EU sanctions laws to suspend or restrict dealings involving the assets and trust.
- Represented a global aerospace firm in an enforcement action led by the State Department Directorate of Defense Trade Controls.