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Practice Areas
Export Controls

Export Controls
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Commodity Jurisdiction (ITAR/EAR) determinations
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ITAR licensing and ITAR-governed agreements
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DDTC/ITAR voluntary disclosures and enforcement matters​
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EAR/BIS classification determinations
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BIS licensing, including deemed exports
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BIS voluntary self-disclosures and enforcement proceedings​
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BIS Entity List compliance and removals
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​Compliance audits, due diligence, and manuals
Economic and Trade Sanctions
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OFAC and U.S. State Department sanctions compliance
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Due Diligence and OFAC 50% Rule Compliance
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Wind-down of sanctioned country business; re-entry of formerly sanctioned countries
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Voluntary self-disclosures to OFAC​
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OFAC penalties and enforcement proceedings, including responding to OFAC administrative subpoenas
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OFAC ​SDN List removal
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Agricultural, medicine, and medical device licensing for sanctioned countries
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Technology, telecoms, and internet services licensing and compliance
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Cuba travel licensing and Cuba Travel Service Provider issues
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Compliance programs, policies, audits, and due diligence
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U.S. Customs and Imports
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Classification (HTSUS) and CBP binding rulings
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Assisting companies on navigating U.S. tariff-related issues, including tariffs imposed pursuant to IEEPA
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Customs Valuation
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Free Trade Agreements, including USMCA verifications
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Country of Origin determinations and marking requirements
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CBP Focused Assessments and audits
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CBP Seizures, protests, and prior disclosures​
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C-TPAT and supply chain security
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​Compliance audits and manuals
Economic and Trade Sanctions
Customs and Imports
FCPA
FCPA & Anti-Money Laundering
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Counseling on the scope of application and requirements of the Foreign Corrupt Practices Act (FCPA) and U.S. anti-money laundering (AML) law
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Integrated FCPA, AML, counter-terrorist financing, and sanctions screening
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FCPA, AML, and reputational risk issues in customer and client onboarding
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Compliance programs, policies, and due diligence


CFIUS & National Security Law
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Advice on whether it is mandatory or advisable to notify the Committee on Foreign Investment in the United States (CFIUS) of a proposed corporate transaction
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Broader US national security analysis of proposed cross-border transactions
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Prepare CFIUS filings, guide parties through the CFIUS process and, when required, negotiate national security mitigation measures with the U.S. Government
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Other U.S. government notifications and regulatory processes for corporate transactions
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Develop due diligence procedures and model clauses to mitigate risks in these areas
Trade Policy
Advising U.S. and non-U.S. clients, including embassies, on international trade-related policy matters, including:
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Section 301 and Section 232 investigations
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Representing importers and foreign governments in Generalized System of Preferences annual reviews conducted by the U.S. Trade Representative (USTR)
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Representing U.S. importers in obtaining duty relief by drafting and submitting Miscellaneous Tariff Bills introduced in the U.S. Congress
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Strategic advice and planning on trends and proposed changes in economic and trade sanctions
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Monitoring legislation affecting international trade pending in the U.S. Congress
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Assisting clients in devising legislative strategies in connection with proposed and pending international trade legislation
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Monitoring developments on multilateral trade matters, such as developments in the World Trade Organization and World Customs Organization

CFIUS
Trade Policy
Trade Remedies

Trade Remedies
We have experience representing companies involved in proceedings arising under the U.S. trade laws governing import relief, including:
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Representing producers and U.S. importers in proceedings at the U.S. Department of Commerce and U.S. International Trade Commission arising under the U.S. trade remedy laws, including antidumping and countervailing duty investigations and reviews
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Represented companies in a large number of U.S. antidumping and countervailing duty cases on behalf of products produced in Thailand, Turkey, Hong Kong, the People's Republic of China, the Netherlands, and Brazil. These cases have involved a wide range of products, including steel pipes and tubes, cold-rolled steel, steel concrete reinforcing bars, chemicals, textiles, agricultural, and industrial products
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Have been involved in Section 201 (“escape clause”) and Section 301 (authorizing retaliation against foreign countries that restrict access to markets) investigations
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Litigated appeals of U.S. government agency decisions in trade remedy cases before the U.S. Court of International Trade and the United States Court of Appeals for the Federal Circuit
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