Contacts
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Paul T. Luther
Partner
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Matthew T. West
Partner
Our International Trade Group regularly advises clients on the full range of applicable U.S. economic sanctions laws, regulations, and policies. We have advised clients extensively on restrictions and requirements under the expanding range of U.S. sanctions laws and regulations, including the Iranian Transactions Regulations, the Sudan Sanctions Regulations, the Cuban Assets Control Regulations, the Iranian Financial Sanctions Regulations, the Comprehensive Iran Sanctions Accountability and Divestment Act of 2010, the National Defense Authorization Act, the Iran Threat Reduction and Syria Human Rights Act of 2012, and implementing Executive Orders.
We offer comprehensive compliance and enforcement advice and representation in U.S. sanctions matters. Services offered include general compliance advice and assistance in formulating and implementing global compliance programs for multinational corporations, as well as due diligence systems reviews and compliance audits in major international acquisitions, with particular experience in the oil and gas sector. In addition, we have extensive experience representing U.S. and non-U.S. companies in international sanctions enforcement actions brought by the U.S. Department of Justice, the U.S. Department of the Treasury (Office of Foreign Assets Control), the U.S. Securities and Exchange Commission, and others. Moreover, we regularly assist clients in obtaining OFAC licenses for transactions involving sanctioned governments and other sanctioned parties. Furthermore, we have assisted publicly traded companies in complying with SEC reporting requirements imposed pursuant to the Iran Threat Reduction and Syria Human Rights Act of 2012. Finally, we regularly provide sanctions compliance training for employees, senior managers and directors, in-house attorneys and staff, and others.
Certain of our recent work in assisting and representing companies in U.S. economic sanctions matters is described below:
- Conducted pre-closing sanctions compliance diligence and systems review and led post-closing trade compliance systems integration of two major multinational oilfield services and supply companies. This project principally involved review and integration of export control and sanctions compliance systems
- Performed comprehensive systems review and assessment of major U.S.-based oilfield equipment manufacturer’s export control, sanctions, antiboycott and FCPA compliance programs; this representation included a review and assessment of company operations in various jurisdictions, including the U.S., Canada, the U.K., Norway and the U.A.E., and the preparation of a detailed report setting forth our findings as well as our recommendations for compliance program enhancements
- Conducted diligence review and trade compliance assessment of overseas acquisition target with extensive operations in the Middle East and North Africa for drilling services company
- Represented a U.S. oilfield services company in far-ranging U.S. government investigation of alleged U.S. support for operations in Iran and Sudan
- Represent multinational oilfield services and engineering company in Department of Justice criminal investigation of alleged violations of U.S. sanctions against Iran, Sudan and Syria
- Represent multinational food products company in obtaining OFAC licenses for a multinational food products company authorizing sales in Iran and Sudan
- Represent U.S. academic institutions and non-profit organizations in seeking OFAC licenses authorizing seminars, symposia, study-abroad programs, and other activities in Iran and Cuba
- Advised online software company regarding compliance with U.S. embargoes and obtained OFAC licenses for activities in Iran and Sudan
- Advised U.S. computer software technology corporation on sanctions compliance in dealings with OEMs and other customers and development of sanctions compliance systems
- Regularly present global and targeted training presentations on a broad range of potential U.S. and trade compliance issues