We have extensive experience in assisting U.S. and non-U.S. companies and financial institutions in complying with the trade embargoes and economic sanctions imposed by the United States, European Union and United Nations. Our experience includes:

 

• Obtaining specific licenses from the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS). These include licenses to permit U.S. companies and their foreign subsidiaries to sell and export medical devices, medicines, agricultural products and technology and telecom equipment or services to embargoed countries (currently Cuba, Iran, North Sudan, North Korea and Syria).

• Guiding companies and financial institutions through discussions of sanctions compliance matters with OFAC and State Department officials.

• Advising multinational companies to ensure that their non-U.S. affiliates are in full compliance with U.S. laws and regulations when engaging in transactions with countries subject to U.S. trade embargoes, including SEC reporting requirements.

• Assisting in the preparation of voluntary-self disclosures to OFAC.

• Defending companies in sanctions enforcement actions brought by OFAC, including responding to OFAC's administrative subpoenas. ​

• Negotiating "special rule" exceptions with the U.S. State Department for non-U.S. companies with former business activities subject to U.S. secondary (extraterritorial) sanctions.

• Obtaining Cuba travel licenses.

• Creating and implementing internal OFAC compliance programs.

• Conducting internal audits and pre-acquisition due diligence relating to sanctions matters.

• Presenting in-house trade compliance seminars and training to U.S. and non-U.S. companies and financial institutions.

• ​Advising art museums and galleries on sanctions-related issues in connection with the import and export of art.

• Assisting individuals and companies in OFAC reconsideration proceedings to be removed from OFAC's List of Specially Designated Nationals (SDN List).