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Export Controls & Economic Sanctions

Experience Highlights

  • As part of the closing of an almost $1 billion transaction, led the investigation and voluntary disclosure of numerous possible ITAR violations, resulting in a quick closeout of the issues at DDTC without fine or penalty

  • Retained by a private equity firm divesting of a line of businesses that included a U.S.-based oil and gas services business on the eve of the close of a transaction to handle all DDTC/ITAR-related requirements and a CFIUS filing which had not been identified by non-U.S. deal counsel; working with the buyer’s counsel from another AMLAW 100 firm, achieved a closeout within 30 days of filing at CFIUS, substantially mitigating disruption to the transaction

  • Retained by a Fortune 100 company to investigate and disclose to DDTC possible ITAR violations of a newly acquired entity

  • Investigated and assisted the client in voluntarily disclosing the possible export to destinations proscribed under the ITAR of certain United States Munitions List (USML)-controlled drawings, resulting in DDTC’s close out of the matter without fine or penalty

  • For a Fortune 100 company, led an investigation, preparation of a voluntary disclosure, and the resolution that disclosure at OFAC without fines or penalties concerning possible violations of the Iran sanctions related to a divestiture of a European operation of the company

  • Retained by a Chinese oil and gas company to address the improper identification of it on numerous state and local government entity sanctions lists for allegedly doing business in Iran

  • Led the buyer’s side on CFIUS, U.S. export control and DSS issues of an acquisition by a foreign-owned entity of a Big Data software company and established a mitigated entity approved by DSS, allowing the company to continue to perform its full array of government contracts and subcontracts

  • Served as lead export/trade regulation counsel on Shougang/BeijingWest Industries’ acquisition of Delphi Corporation’s automobile parts business, which was named by Asian-Counsel magazine as one of the “Deals of the Year 2009”

  • Represented software manufacturers and e-commerce businesses on compliance with export regulations over encryption-capable products and technology, including export compliance issues and licensing associated with employment of foreign persons in the U.S