Our experience includes all aspects of investigations and enforcement, counseling and compliance as set forth below.

Investigations and enforcement

Examples of recent investigation and enforcement matters include:

Internal audits and investigations

• Comprehensive worldwide multi-year audit of a flow control product and service company's export, sanctions and ITAR compliance activities
• Internal investigation of international automobile manufacturer's export activities
• Audit of international telecommunication company's activities in Indonesia
• Internal investigation of major U.S. University's ITAR related dealings
• Audit of hospital's export and sanctions compliance program
• Internal investigation of U.S. located trading company's indirect activities in sanctioned countries. 
• Audit of spherical aluminum powder manufacturer's export and ITAR compliance program
• Internal investigation of global engineering and construction company's activities in sanctioned countries
• Internal investigation of software company's anti-corruption compliance
• Audit of oil services company's compliance program
• Internal investigation of oil field communication company's anti-corruption compliance
• Audit of international distributor of consumer good's compliance program
• Internal investigation of global engineering and construction company's activities related to Iran
• Internal investigation of global manufacturer of dental equipment's potential export activities
• Audit of surveillance equipment manufacturer's compliance program
• Internal investigation of technology company's anti-corruption compliance

Government investigations and enforcement actions

• Representing U.S. oil field services company in a multi-agency investigation of alleged violations of U.S. sanctions programs, export control regulations, anti-corruption laws and the United Nations Oil-For-Food program
• Representing engineering and construction company in anti-boycott enforcement matter by U.S. Department of Commerce
• Representing distributor of consumers goods in a grand jury investigation into potential violations of U.S. export restrictions on Syria
• Representing food industry company in anti-boycott enforcement matter by U.S. Department of Commerce
• Representing major U.S. petrochemical company in OFAC investigation into potential sanctions violations
• Representing distributor of electronic components in DOJ investigation of potential U.S. export control violations
• Representing major U.S. energy sector company in multi-agency investigation of potential violations of the United Nations Oil-For-Food program
• Representing multinational oilfield service companies in investigations relating to potential violations of the United Nations Oil-For-Food program
• Representing machine tool manufacturer on U.S. Customs enforcement matter
• Representing manufacturer of air conditioning products on U.S. Customs enforcement matter
• Representing specialty vehicle manufacturing company in U.S. Department of Commerce export enforcement matter
• Representing manufacturer of high technology communications devices in Congressional investigation into potential ITAR violations
• Representing subsidiary of world-leading defense contractor in multijurisdictional civil and criminal investigations involving DOJ, UK Serious Fraud Office and Her Majesty's Revenue and Customs regarding export control and sanctions

Voluntary self-disclosure

• Drafting and submitting voluntary self-disclosures to BIS, DDTC and OFAC on behalf of flow control product and service company relating to potential EAR, ITAR and sanctions violations
• Drafting and submitting voluntary self-disclosure to DDTC on behalf of a marine safety and survival equipment manufacturer regarding ITAR related activities
• Drafting and submitting voluntary self-disclosure to DDTC on behalf of University relating to potential ITAR issues
• Drafting and submitting voluntary self-disclosure to OFAC on behalf of an oil and gas exploration company relating to potential Libyan sanctions issues
• Drafting and submitting voluntary self-disclosure to DDTC on behalf of aluminum powder manufacturer
• Drafting and submitting voluntary self-disclosures to OFAC and BIS concerning potential EAR and sanctions violations on behalf of international offshore drilling company.

Counseling

Examples of recent counseling matters include:

Export and trade of dual use goods, software and technology (including encryption)

• International automobile manufacturer on U.S. export control laws
• Oil field communications company on U.S. export control laws
• Distributor of consumer goods on U.S. export control laws regarding Syria
• Software authentication company on U.S. encryption export control laws
• Manufacturer of fluorinated products on U.S. anti-dumping laws related to the import of polytetrafluoroethylene products
• Oil field services company on U.S. export control laws
• Aircraft manufacturing and leasing companies on U.S. export control laws
• International distributor of consumer goods on U.S. export control laws
• Energy company on Department of Energy export control regulations relating to natural gas liquids
• Distributor of electronic components on U.S. export controls laws
• Health care facility on U.S. export controls related to specimens of threatened species
• Defense manufacturer on U.S. export control laws
• University on export control laws relating to cloud computing
• Specialty vehicle manufacturing company on U.S. export control laws
• Multinational banking and securities company on U.S. export control laws
• Medical device manufacturer on U.S. export control laws
• Microprocessor and semiconductor manufacturer on U.S. export control laws
• International equipment manufacturing and distributing company on U.S. export control laws
• Building product manufacturer on U.S. export control laws
• Canadian energy company on U.S. export control laws
• Offshore drilling company on U.S. export control laws
• Security glass manufacturer on U.S. export control laws
• Oil and gas services company on U.S. export control laws
• International telecommunications company on U.S. export control laws
• Global engineering and construction company on U.S. export control laws
• Seismic equipment manufacturer on U.S. export control laws
• Canadian oil field equipment manufacturer on U.S. export control laws
• Petroleum product trading company on U.S. export control laws
• Indian automotive manufacturer on U.S. export control laws
• International well servicing company on U.S. export control laws
• Machine tool manufacturer on U.S. export control laws
• International hotel group on U.S. export control laws and trade restrictions in Syria
• Manufacturer of forged products on U.S. export control laws
• International energy services company on U.S. export control laws
• Marine contractor and operator of offshore oil and gas properties regarding U.S. export control laws
• Manufacturer of spherical aluminum powder on U.S. export control laws
• Manufacturer of satellite earth stations on U.S. export control laws
• Manufacturer of proppant products on U.S. export control laws
• International catalytic process company on U.S. export control laws
• Manufacturer of graphite products on U.S. export control laws
• Saudi Arabian manufacturer of piping products on U.S. export control laws
• International oil exploration and production company on U.S. export control laws
• University on U.S. deemed export regulations
• University on U.S. export control laws related to establishing a satellite facility in the Middle East
• Austrian steel manufacturer on U.S. export control laws
• Energy services company on U.S. export control laws related to shipments of crude petroleum via oil pipelines
• Energy marketing and trading company regarding U.S. export control laws related to the export of crude oil and natural gas liquids

Economic sanctions and embargo regulations

• International automobile manufacturer on U.S. sanctions regulations
• Oil and gas exploration company on Libyan sanctions regulations
• Global engineering and construction company on Iran sanctions
• Petrochemical company on U.S. sanctions regulations
• Oil field services company on U.S. sanctions regulations
• International catalytic process company on U.S. sanctions regulations
• Medical device manufacturer on U.S. sanctions regulations
• Aircraft manufacturing and leasing companies on U.S. sanctions
• International energy services company on U.S. sanctions regulations
• Microprocessor and semiconductor manufacturer on U.S. sanctions regulations
• International well servicing company on U.S. sanctions regulations
• Defense manufacturer on U.S. sanctions regulations
• Building product manufacturer on U.S. sanctions regulations
• International oil exploration and production company on U.S. sanctions regulations
• Manufacturer of proppant on U.S. sanctions regulations
• Canadian energy company on U.S. sanctions regulations
• International hotel group on U.S. sanctions regulations
• Oil and gas services company on U.S. sanctions regulations
• Investment company on U.S. sanctions regulations
• Manufacturer of spherical aluminum powder on U.S. sanctions regulations
• International telecommunications company on U.S. sanctions regulations
• Oil field services company on withdrawing from sanctioned countries
• Indian automotive manufacturer on U.S. sanctions regulations
• University on U.S. sanctions regulations relating to cloud computing
• Manufacturer of pumps, seals and valves on withdrawing from sanctioned countries
• Seismic equipment manufacturer on U.S. sanctions regulations
• Manufacturer of products on U.S. Sanctions regulations
• International equipment manufacturing and distributing company on U.S. sanctions regulations
• Electronics company on U.S. sanctions regulations
• International bank on U.S. sanctions regulations
• Offshore drilling company on U.S. sanctions regulations
• Global engineering and construction company regarding U.S. sanctions regulations
• Canadian oil field equipment manufacturer on U.S. sanctions regulations
• Market research company on U.S. sanctions regulations and access to web surveys by parties in sanctioned countries
• Machine tool manufacturer on U.S. sanctions regulations
• Manufacturer of forged products on U.S. sanctions regulations
• Marine contractor and operator of offshore oil and gas properties on U.S. sanctions regulations
• Saudi Arabian manufacturer of piping products on U.S. sanctions regulations
• University on U.S. sanctions regulations related to establishing a satellite facility in the Middle East
• Austrian steel manufacturer on U.S. sanctions regulations
• Industrial brand management company on EU sanctions regarding shipment of goods to Iran
• Global leader in consumer goods sector regarding issues arising out of UN Trade sanctions against North Korea
• World leading defense sector company regarding developments in UK and EU trade controls and authorization of transactions under UK and EU international trade and sanctions laws
• International telecommunications company on EU sanctions on Ivory Coast
• Manufacturer of dental equipment regarding developments regarding EU sanctions on Iran
• Aircraft leasing company on provisions in lease agreement regarding compliance with export trade and sanctions
• Offshore drilling company on EU sanctions on Ivory Coast and movement of goods from Ivory Coast to Cameroon

Export and trade of defense and aerospace goods, services and technical data

• Flow control product and service company on ITAR compliance
• Manufacturer of marine safety and survival equipment on ITAR compliance and ATF import requirements
• University on ITAR compliance
• Aircraft parts manufacturer on ITAR compliance
• International materials manufacturer on ITAR compliance and Canadian exemptions
• Defense manufacturer on ITAR compliance
• Manufacturer of security glass products on ITAR compliance
• Manufacturer of spherical aluminum powder on ITAR compliance
• Prototyping, manufacturing, tooling and injection molding services company on ITAR compliance and hiring of foreign national employees
• Manufacturer of surveillance equipment on ITAR compliance
• Manufacturer of high technology communication devices on ITAR compliance
• Manufacturer of valves and pumps for use in naval vessels on ITAR compliance

Anti-boycott regulations

• Multi-national banking and securities company on Department of Commerce and Treasury anti-boycott regulations
• Major U.S. oil and gas company on Department of Commerce and Treasury anti-boycott regulations
• International soft drink manufacturer on Department of Commerce and Treasury anti-boycott regulations relating to operations in the Middle East
• Equipment manufacturing and distributing company on Department of Commerce and Treasury anti-boycott regulations
• University on Department of Commerce and Treasury anti-boycott regulations
• Chemical manufacturer on Department of Commerce and Treasury anti-boycott regulations
• Global engineering and construction company on Department of Commerce and Treasury anti-boycott regulations
• Aero structures manufacture on Department of Commerce and Treasury anti-boycott regulations
• Milling and marketing company on Department of Commerce and Treasury anti-boycott regulations
• Multinational banking and securities company on Department of Commerce and Treasury anti-boycott regulations
• Seismic equipment manufacturer on Department of Commerce and Treasury anti-boycott regulations
• International equipment manufacturing and distributing company on Department of Commerce and Treasury anti-boycott regulations

Anti-corruption regulations

• Oil field communications company on anti-corruption laws
• Medical device manufacturer on anti-corruption laws
• Oil and gas services company on anti-corruption laws
• Software company on anti-corruption laws
• Global engineering and construction company on anti-corruption laws
• Seismic equipment manufacturer on anti-corruption laws
• International telecommunications company on anti-corruption laws
• Building product manufacturer on anti-corruption laws
• Manufacturer of forged product on anti-corruption laws
• Producer of engineered polymer powders regarding potential FCPA issues
• International well servicing company on anti-corruption laws and obligations
• Global transportation company regarding FCPA compliance
• Security company on FCPA compliance
• Major financial institution on anti-corruption laws
• Technology company on anti-corruption laws

U.S. Customs laws and free trade agreements

• Coating resin manufacturer on U.S. import and drawback requirements
• Security glass manufacturer on U.S. Customs regulations
• Health care facility on importing specimens of endangered species
• Manufacturer of air conditioning products on U.S. Customs and NAFTA regulations and origin requirements
• Machine tool manufacturer on U.S. Customs regulations
• Importers on U.S. Customs wood and phytosanitary import procedures requirements
• Manufacturer of forged products on NAFTA origin issues
• Pharmaceutical company on U.S. Customs regulations and classification of products
• Manufacturer of juice products on U.S. Customs regulations and marking requirements
• Manufacturer of dairy products on U.S. Customs regulations and dairy import quotas.
• Manufacturer of insecticides on U.S. Customs regulations
• Austrian steel manufacturer on U.S. Customs regulations
• Manufacturer of beef products on U.S. Customs regulations and import quotas
• Manufacturer of consumer goods on the generalized system of preferences (GSP)
• Petroleum and natural gas company on U.S. Customs law and free trade agreements
• Distributor of food products on U.S. Customs and NAFTA requirements
• Distributor of electronic components on U.S. Customs regulations and counterfeit goods import issues
• International forklift manufacturer regarding U.S. Customs regulations related to royalty payments and Trade Agreements Act (TAA) certification
• Advising chemical manufacturer on NAFTA marking rules
• Counseling apparel manufacturer on NAFTA valuation and marking rules
• Advising importer-exporter on drawback requirements

Committee on foreign investment in the United States ("CFIUS")

•  Advising international investment fund contemplating acquisition of U.S. port on CFIUS requirements
• Advising Chinese petroleum company on CFIUS requirements

Money laundering

•  Advising major investment fund on anti-money laundering (Patriot Act) and know-your- customer requirements
• Advised multi-industry global company regarding possible money laundering issues in foreign sector operations

Compliance

Examples of recent compliance matters include:

Comprehensive trade control compliance programs and contractual language

•  Developing and implementing tailored and comprehensive export compliance program for medical device manufacturer
• Developing and implementing tailored comprehensive export compliance program for Canadian oil field equipment manufacturer
• Drafting export and sanctions compliance contractual language for aircraft manufacturers and leasing companies
• Developing and implementing tailored comprehensive export, sanctions and anti-corruption compliance program for oil rig operating company
• Drafting export and sanctions compliance acquisition contractual language for financial institutions
• Developing and implementing tailored export, sanctions, anti-boycott and anti-corruption compliance policies and procedures for international telecommunications company
• Developing and implementing export, sanctions and anti-corruption compliance policies and procedures for international well servicing company
• Developing and implementing export, sanctions and anti-corruption compliance policies and procedures for Latin American petroleum company

 Pre- and post- merger/acquisition due diligence and risk assessment

•  Pre-joint venture export compliance due diligence for international oil exploration and production company
• Pre-acquisition anti-corruption due diligence for global engineering company
• Pre-acquisition export, sanctions and anti-corruption due diligence for major energy company
• Pre-joint venture export, sanctions and anti-corruption due diligence for major financial institution
• Pre-acquisition anti-corruption due diligence for major defense company
• Post-acquisition anti-corruption due diligence for international oil services company

 Third party due diligence

• Export control, sanctioned country and anti-corruption due diligence for forged product manufacturer

Export authorization

•  Advising manufacturer of marine safety and safety equipment on technical assistance agreements (TAA)
• Drafting and submitting license application to OFAC on behalf of oil and gas exploration company relating to potential transactions in Libya
• Drafting and submitting export license request to BIS for crude oil products
• Drafting and submitting export license requests to BIS for machine tools
• Drafting and submitting license request to DDTC related to the hiring of foreign national employees on behalf of prototyping, manufacturing, tooling and injection molding services company
• Drafting and submitting license request to OFAC on behalf of non-profit authorizing export of agricultural and medical products to Sudan
• Drafting and submitting license request to OFAC on behalf of UK investment company to release securities subject to U.S. Cuban Asset Control Regulations

 Classification requests

•  Drafting and submitting classification requests to BIS on behalf of machine tool manufacturer
• Drafting and submitting classification requests to BIS on behalf of satellite earth station manufacturer
• Drafting and submitting classification requests to BIS on behalf of valve, pump and seal manufacturer
• Drafting and submitting classification requests to BIS on behalf of pump manufacturer
• Drafting and submitting classification requests to BIS on behalf of petroleum product trading company

 ITAR registration

• Drafted and submitted ITAR registration on behalf of marine safety and survival equipment manufacturer

Commodity jurisdiction requests

• Drafted commodity jurisdiction request to DDTC on behalf of flow control product manufacturer
• Drafted commodity jurisdiction request to DDTC on behalf of defense manufacturer

Training presentations

•  Training employees of international equipment manufacturing and distributing company on U.S. export control, sanctions and anti-boycott regulations
• Training insurance executives regarding dealing with regulations in investigative and customs settings
• Training members of a free trade alliance on U.S. export control, sanctions and anti-corruption laws
• Training worldwide employees of flow control product manufacturer on U.S. export control, sanctions, ITAR and anti-corruption regulations
• Training employees of pump manufacturer on U.S. export control and sanctions laws
• Training employees of manufacturer of graphite products on U.S. export control and sanctions lawsTraining employees of manufacturer of spherical aluminum powder on U.S. export control and ITAR regulations

U.S. Customs

•  Drafting petition to Customs on behalf of distributor of electronic components regarding relief from forfeiture of counterfeit goods
• Drafting petition to Customs on behalf of manufacturer of air conditioning products regarding relief from forfeiture of air conditioning parts
• Drafting petition to Customs on behalf of machine tool manufacturer regarding relief from forfeiture of machine tools

CFIUS

• Drafting CFIUS filing on behalf of international investment fund contemplating acquisition of U.S. port