International Trade

LEADERS

Overview

Doing business internationally in the 21st century poses a multitude of challenges for companies striving to comply with various U.S. and foreign international trade- and national security-based regulatory restrictions and requirements.  Gibson, Dunn & Crutcher’s International Trade lawyers understand the intricacies of these challenges, and can help you quickly and cost-effectively navigate these complex regulatory regimes.  Our lawyers have represented multinational corporations in some of the most legally complex and politically sensitive international trade cases in recent years.  Few other firms can match our global presence, comprehensive experience and deeply talented team.

Named by Law360 as its 2012 International Trade Group of the Year, Gibson Dunn’s International Trade Practice Group is centered in the Washington, D.C. office, located near the federal departments and agencies that implement and enforce U.S. import, export, customs, transnational investment and unfair trade laws and regulations.  Lawyers in the practice group assist both U.S. and international clients on a wide variety of trade-related matters, including:

  • Antidumping and countervailing duties: import relief
  • Customs
  • Economic and trade sanctions
  • Export controls
  • Transnational business and foreign direct investment controls (CFIUS)
  • Trade litigation and agency representation
  • Trade and investment policy
  • World Trade Organization (WTO) and other foreign sovereign claims
  • National security
  • Due to the increasing complexities attendant on doing business internationally, and to ensure the comprehensive representation of your needs, our
  • International Trade lawyers work closely with a wide array of other Gibson Dunn practice groups throughout our transactional and litigation departments.

For example, with the continued expansion of U.S. businesses into transitional economies where government corruption continues to be a reality, familiarity with the U.S. Foreign Corrupt Practices Act (FCPA) is crucial.  In coordination with our securities and white collar litigation practices, the International Trade group often advises U.S. multinational companies and their representatives abroad on various anti-corruption and anti-terrorist financing compliance matters, including FCPA issues relating to sales agents, joint ventures, acquisitions and competition for foreign government contracts.  We also advise on structuring compliance training programs to conform with FCPA prohibitions and securities law requirements.  Our International Trade lawyers also work very closely with the firm’s anti-money laundering practitioners to provide advice on anti-money laundering compliance and representation in connection with financial institution regulatory enforcement actions and examinations.

We serve as defense counsel in proceedings involving the U.S. Justice Department, the Securities and Exchange Commission and the U.S. courts.  We are well known for acting as compliance monitors and/or in advising those monitors.  We also advise on EU and individual European country compliance and enforcement matters.

EXPERIENCE & RECENT REPRESENTATIONS

Gibson Dunn’s International Trade group has represented multinational corporations in some of the most legally complex and politically sensitive international trade cases in recent years.  We handle “escape clause” cases under the U.S. 1974 Trade Act and “national security” investigations under the U.S. Trade Expansion Act.  Client work additionally includes unfair trade practices and fact-finding investigations under the U.S. Tariff Act of 1930.

Practice group members are skilled in antidumping and countervailing duty investigations, administrative reviews and five-year “sunset” reviews before the U.S. International Trade Commission and Department of Commerce.  Our lawyers have represented clients in various appeals of import relief measures before the U.S. Court of International Trade and the Federal Circuit.  They participate as well in international dispute settlement proceedings.

Recent representations include:

  • Antidumping and countervailing duty investigations and/or administrative reviews involving products such as semiconductors, steel, film, agricultural products, lumber, antifriction bearings, apparel, polyester fiber, chemicals and automotive products.
  • Sunset reviews of antidumping and countervailing duty orders on products such as industrial chemicals, industrial belts, grain-oriented electrical steel and corrosion-resistant carbon steel.
  • Section 201 cases concerning products such as steel wire rod and circular carbon-quality welded line pipe.
  • Section 337 investigations of matters including alleged chemical and electronic product patent violations.
  • Section 332 general fact-finding studies of agricultural, steel, and automotive products.

Complete NAFTA Guidance

The North American Free Trade Agreement has greatly expanded trade among the United States, Mexico and Canada.  These countries are now the United States’ most important trading partners.  Many NAFTA rules, however, are complex and difficult to apply.  With many lawyers concentrating in NAFTA issues, our practice group is able to provide the expert guidance to assure that our clients conform with all NAFTA requirements.

We advise on determining proper country of origin for NAFTA purposes in order to obtain the best possible duty rate.  Our lawyers possess specialized knowledge in a number of product areas, including the textile and automotive sectors.  We counsel on NAFTA marking requirements, helping clients avoid marking penalties, and we work with clients to assure compliance with NAFTA’s unique duty deferral and drawback rules.

We can assist with establishing and operating cross-border manufacturing operations in order to take full advantage of the Mexican maquiladora program.  And as necessary we counsel on the procedures for accessing the NAFTA dispute resolution processes.

Other Preferential Regimes

Our lawyers additionally have capabilities with a range of other preferential trade regimes.  In addition to the numerous bilateral investment agreements that are now in place or under negotiation, our experience extends to:

  • The Generalized System of Preferences
  • The Caribbean Basin Initiative
  • The United States-Israel Free Trade Area

Companies doing business internationally today must ensure that they comply with myriad economic and trade sanctions administered and enforced by a host of governmental bodies and international organizations around the world seeking to combat international terrorism, nuclear weapons proliferation, drug trafficking and other breaches of international law.  Unilateral or multilateral, broad or targeted, country-based or list-based, complementary or conflicting, violation of these sanctions can lead to significant civil or criminal penalties, can subject a company to being placed on a “blacklist” for even inadvertent violations, and can irreparably damage a company’s reputation in the global marketplace.

The lawyers on our global sanctions team have extensive experience advising clients operating internationally on how best to navigate this complex web of varying obligations and restrictions.  Serving clients in nearly every industry sector and around the globe, we routinely advise on a wide array of compliance issues arising from the various U.S. and foreign sanctions laws and regulations.

Our work is as varied as our client base and includes:

  • Assisting with the design and implementation of compliance systems, policies and procedures
  • Conducting compliance assessments and risk audits
  • Advising on the scope and applicability of particular sanctions regulations
  • Liaising with key officials and regulators to obtain guidance or insight on policy focus and direction
  • Preparing requests for official advisory opinions or licenses

When a company is concerned that sanctions violations may have occurred, we regularly assist in conducting an internal investigation, and in preparing and submitting any required self-disclosures.  We routinely represent companies before regulators and enforcement agencies when the government decides to launch an official investigation.

Gibson, Dunn & Crutcher’s International Trade lawyers routinely counsel clients on compliance with the Export Administration Regulations (EAR) administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS), and the International Traffic in Arms Regulations (ITAR) enforced by the U.S. Department of State, Directorate of Defense Trade Controls (DDTC).  Our export control practice includes professionals who have extensive experience in public service in the U.S. Congress and at the various governmental agencies that administer the U.S. export control laws and regulations, and who continue to maintain excellent contacts with and access to key decision makers.

Our wide range of services for clients dealing with export control issues includes:

  • Development of ITAR and EAR export compliance programs
  • Analysis of the United States Munitions List (USML) and Commerce Control List (CCL), and preparation of commodity jurisdiction requests
  • Assistance with navigating the changes brought on by Export Control Reform, as commodities and items shift from the USML to the CCL
  • Assistance with encryption registration and reporting requirements and procedures
  • Preparation of registration statements (including amendments triggered by changes in corporate structure or ownership)
  • Preparation and submission of license applications and advisory opinion requests
  • Preparation and submission of Technical Assistance Agreements (covering a wide variety of situations, including transfers of military technology to new foreign owners, collaboration with foreign parties on defense-related projects, releases of defense technology and provision of training to foreign nationals located in the United States)
  • Conduct of extensive internal investigations involving potential ITAR/EAR violations
  • Preparation and submission of voluntary disclosure filings (with the State Department, the Defense Department, and/or the Commerce Department)
  • Coordination with State Department (DDTC), the Defense Department (DTRA), and the Commerce Department (BIS) on all of the above issues

Gibson, Dunn & Crutcher’s lawyers routinely handle complex cross-border investment transactions, and have considerable expertise in U.S. regulation of foreign investment, including Exon-Florio reviews before the inter-agency Committee on Foreign Investment in the United States (CFIUS).  We advise both acquiring companies and targets in evaluating the potential benefits of a voluntary CFIUS filing, and counsel clients during all aspects of the CFIUS process, from the “pre-filing” notification to the closing letter.

Complementary to its CFIUS practice, Gibson Dunn offers industry-leading capabilities through practice groups in Government Contracts, Antitrust and Competition, Mergers and Acquisitions, Tax, Global Finance, Energy and Infrastructure, and Public Policy.  These combined strengths uniquely position our firm to provide CFIUS advice that is seamlessly integrated into the entire acquisition or sale transaction.  Because CFIUS is an inter-agency entity, parties must be prepared to navigate issues that might be raised from a wide variety of governmental stakeholders.  Under the CFIUS umbrella, government interest items may include, among others, issues related to the National Industrial Security Program (NISP) such as developing a FOCI (Foreign Ownership, Control or Influence) action plan acceptable to the Department of Defense, and other agencies’ regulatory requirements, such as those of the Federal Energy Regulatory Commission (FERC).  CFIUS parties may even be required to work with the U.S. Congress in particularly sensitive, high-stakes matters.

Navigating Foreign Boycotts

U.S. tax and export administration laws also penalize or restrict compliance by U.S. companies with foreign boycotts.  U.S. and multinational companies, especially those doing business in the Middle East, confront a conflicting array of local laws requiring compliance with boycott requirements and U.S. laws prohibiting or limiting compliance and imposing significant reporting obligations.  Our practice group advises on the establishment and maintenance of compliance programs and the analysis and resolution of the conflicting requirements of U.S. and local boycott laws.  We also represent clients in the resolution of antiboycott issues before the U.S. Internal Revenue Service and the Department of Commerce’s Office of Antiboycott Compliance.

​Trade Litigation

Gibson, Dunn & Crutcher does not limit its international trade practice to appearances before administrative agencies. The group has represented many clients in appeals of international trade and customs cases before the U.S. Court of International Trade and the Federal Circuit.

Gibson, Dunn & Crutcher lawyers guide clients to develop and implement global trade strategies based on current trade law and negotiations for future trade agreements.  Our lawyers have capabilities with a range of preferential trade regimes, including the North American Free Trade Agreement (NAFTA), and in the intricacies of exports and foreign direct investment.  Our practice group members also provide counsel in understanding the implications of World Trade Organization (WTO) panel reports, and represent clients before United Nations tribunals.

For example, the United States has been involved in numerous trade negotiations that include:

  • The Doha Round
  • Bilateral trade and investment agreements
  • WTO accession agreements involving issues such as the investment laws of Saudi Arabia and the Newly Independent States
  • Asia-Pacific Economic Cooperation (APEC)
  • The Organization for Economic Co-operation and Development (OECD)
  • Multilateral investment agreements

WTO and Other International Organizations
Gibson, Dunn & Crutcher works with clients to develop responses, in conjunction with their governments, to activities considered to be inconsistent with the rules promulgated by the World Trade Organization.  Our practice group members also provide counsel in understanding the implications of WTO panel reports, and represent clients before United Nations tribunals.

Recent representations include:

  • Won for client a $505 million award, from the United Nations Compensation Commission, as compensation for losses caused by Iraq’s invasion and occupation of Kuwait in August 1990.  This was the largest UNCC award made to any U.S. corporate claimant.

Since the terrorist attacks of September 11, 2001, the U.S. government is increasingly active in monitoring international business transactions and in regulating or restricting business activities in response to the threat of physical, electronic or financial terrorism.  Doing business in the 21st century raises a number of national security issues – supply-chain security management; border security; emergency response and recovery; restrictions on the export of certain technologies; and complying with economic trade sanctions, anti-money laundering requirements and anti-corruption regimes.

Gibson, Dunn & Crutcher’s extensive experience in all areas of global commerce, coupled with its nationally recognized expertise in dealing with both U.S. and foreign laws and regulations, allows us to handle and solve our clients’ most vexing problems.

Our National Security team is drawn from several practice groups throughout the firm, including Crisis Management, Financial Institutions, Government Contracts, International Trade, Labor and Employment, Public Policy, Litigation, and White Collar Defense and Investigations.  The National Security team includes partners, senior lawyers and others with extensive government experience, top security clearances and wide-ranging capabilities in the full spectrum of national security issues.

Many of the members of our team have served in senior capacities in the federal government, particularly in the agencies and organizations that make, implement and enforce national security laws and regulations.  Our team includes lawyers who have held high-level positions in the U.S. Departments of Justice, Treasury and Labor, as well as the White House, the National Security Council and the Office of Management and Budget (OMB).  Members of the team include a former U.S. Attorney for Los Angeles, a legal advisor to the National Security Council, two Solicitors for the U.S. Department of Labor, the Associate Director of OMB, and an Assistant General Counsel in the Central Intelligence Agency (CIA)’s Office of General Counsel.  While in government, our lawyers also worked closely with every national security-related agency, including the Director of National Intelligence, the CIA, the National Security Agency (NSA), the Defense Security Service and the Department of Homeland Security.  Given this wealth of experience, we are prepared to address every aspect of a national security legal or public policy issue facing our clients.

The ongoing conflicts in Iraq and Afghanistan and elsewhere often raise issues that require knowledge of those countries’ laws and procedures, and experience with contingency operations.  Gibson Dunn lawyers have represented clients across the entire spectrum of battlefield conditions, from peace operations, support and stability operations to full-scale armed conflict and post-conflict environments in locations such as Afghanistan, Iraq and Kuwait.  Gibson Dunn is fortunate, and proud, to have on its team over a dozen former military officers.  Our lawyers have extensive experience representing contractors and individuals in theater and are highly knowledgeable about the laws, regulations and challenges clients face when performing work in a battlefield environment.

A number of Gibson Dunn’s team members either currently hold, or have recently held (and can reactivate on short notice) security clearances through the Top Secret/SCI level.  This allows us to get involved rapidly in matters where access to classified material is required and time is of the essence.

Set forth below are some of the most common concerns our clients confront in the national security realm and a brief summary of our experience in those areas.  Specific information about the work we do in these areas can be found in the various practice group descriptions.

Economic Sanctions and Embargoes (Office of Foreign Assets Control)

Members of our International Trade and White Collar Defense groups advise both U.S. and foreign clients engaged in international commerce on a wide array of issues stemming from compliance with U.S. sanctions and embargoes administered and enforced by the Department of the Treasury, Office of Foreign Assets Control (OFAC) and the Department of State.  Lawyers in these groups have substantial experience assisting companies with conducting compliance assessments and risk audits, advising on the scope and applicability of particular sanctions regulations, liaising with key officials and regulators to obtain guidance or insight on policy focus and direction, or preparing requests for official advisory opinions or licenses.  When a company is concerned that sanctions violations may have occurred, we frequently assist in the internal investigation to uncover the facts, prepare and submit any self-disclosures and, if necessary, represent the company during the course of a subsequent government investigation or enforcement action.

Export Controls

Our International Trade and Government Contracts groups advise clients on a wide range of U.S. government restrictions on the export of goods and technologies.  Our clients regularly consult us for advice on complying with the Export Administration Regulations and the International Traffic in Arms Regulations.  We assist clients in developing effective programs to ensure compliance with license conditions and reporting requirements, and in responding to enforcement actions.  We also assist clients in obtaining licenses and other authorizations from the Commerce Department’s Bureau of Industry and Security (BIS) and the State Department’s Directorate of Defense Trade Controls (DDTC).

Foreign Corrupt Practices Act and International Bribery Compliance and Investigations

As clients expand business opportunities overseas, the risk of corruption and bribery has increased exponentially.  Moreover, the Justice Department’s recent announcement that it considers Foreign Corrupt Practices Act (FCPA) enforcement to be a national security issue tied to the global fight against terrorism makes the FCPA even more important.  Our White Collar Defense and International Trade groups have represented clients in investigations involving alleged violations of the FCPA since the inception of the law.  Our lawyers regularly advise clients on all aspects of the FCPA and multinational corruption issues, including:  initial advice, training, establishment and implementation of effective compliance programs, representation in internal and government investigations involving suspected FCPA and international corruption violations, Securities and Exchange Commission implications of FCPA issues, merger and acquisition due diligence related to corporate transactions, and special engagements such as serving in corporate compliance monitorships.

Foreign Investment

Our International Trade, Government Contracts and Public Policy groups have extensive experience assisting both U.S. and foreign companies in transactions subject to review by the Committee on Foreign Investment in the United States (CFIUS).  In addition, when companies are determined to be under foreign ownership, control or influence (FOCI), we have assisted in obtaining security clearances and handling other issues to enable our clients to obtain or retain federal government work.

Government Contracts

Our Government Contracts group has decades of experience providing counseling and litigation services to defense industry and commercial clients regarding national security implications of their business relationships with the U.S. government.  We have been involved in numerous hearings and disputes, conducted entirely in the “black world,” on precedent-setting cases involving the State Secrets privilege and the Defense Production Act.  We have represented clients in matters involving the CIA, the NSA, the National Reconnaissance Office, the National Geospatial Intelligence Agency, and other federal agencies involved in intelligence gathering and analysis.  We regularly work with companies before the Defense Security Service and assist them in satisfying the regulatory requirements of the National Industrial Security Program (NISP) that are driven by foreign investments or acquisitions.  In addition, we have been called upon to represent U.S. government agencies on several occasions.

Homeland Security/SAFETY Act

Our Government Contracts, Crisis Management and Public Policy groups have counseled companies since September 11, 2001, on issues relating to what has become known as Homeland Security.  We have counseled clients on qualifying their products under the SAFETY Act, addressing company-threatening liability for pharmaceutical products, and other first-impression matters.

Information Security

Our International Trade group advises clients on the restriction of exports on encryption technology.  In addition, our Privacy, Cybersecurity and Consumer Protection and White Collar Defense groups represent clients in matters involving charges of computer hacking, intrusion and intellectual property offenses, as well as entities that have been victimized by network security incidents or data breaches.

National Security Civil and Criminal Litigation

Increasingly, our clients are confronting civil litigation and criminal investigations that raise national security issues.  Members of our Litigation and White Collar Defense groups have deep experience in such matters.  Often the resolution of these cases turns on classified information, and our lawyers are well versed in the complex procedures for handling classified information in the federal courts, including the Classified Information Procedures Act and the State Secrets privilege.

National Security Public Policy

The members of our Public Policy group also have extensive experience with effecting public policy change on national security matters.  We are prepared to help build strategies regarding national security policy matters pending before both the Congress and the Executive Branch.  Our team includes a former high-ranking State Department official and a former member of the National Security Council staff responsible for providing advice to White House and Executive Branch policymakers and addressing congressional oversight of national security programs.

Anti-Money Laundering

Members of our Financial Institutions and White Collar Defense groups have extensive knowledge of U.S. and foreign anti-money laundering laws and regulations, both as government lawyers and private practitioners.  We provide advice on anti-money laundering and forfeiture laws, currency transaction reporting, the identification and reporting of suspicious activity, wire transfer and other record-keeping requirements.  We advise and represent financial institutions in audits and exams conducted by a number of regulators and help prepare our clients to successfully complete the exercises in the most cost-effective manner.  We also defend financial institutions and other regulated entities against investigations and prosecutions for failure to prevent or report illegal money laundering and failure to follow the “know-your-customer” requirements and other requirements of the USA PATRIOT ACT.  Our clients include banks and financial service companies, as well as major international businesses, including manufacturers and distributors of appliances, consumer electronics, computers, and other goods.

Congressional Investigations

Our Public Policy group has extensive experience advising defense and high-tech industry clients in their interaction with federal, state and local governments.  We have prepared clients to testify before Congressional committees, assisted foreign firms in obtaining approvals from regulatory agencies to acquire U.S. defense contractors, defended technology clients against hostile takeover bids based on national security concerns, and assisted defense and aerospace firms with advocacy issues both in the United States and in foreign countries.

Customs and Imports

Our International Trade group represents clients in compliance, licensing and enforcement matters before the Department of Homeland Security’s Bureau of Customs and Border Protection (CBP) and Immigration and Customs Enforcement (ICE).  We have particular expertise shepherding our clients through a customs compliance assessment or audit and with the Customs-Trade Partnership Against Terrorism (C-TPAT) program.

E-Verify/Employment Issues

Our Labor and Employment group has extensive experience with the full range of employment issues facing employers in the post-9/11 environment, including the E-Verify system, which requires federal government contractors to use an electronic verification system to verify the employment eligibility of new employees.

RECENT PUBLICATIONS

Developments in the Defense of Financial Institutions

-July 13, 2018

California Consumer Privacy Act of 2018

-July 12, 2018

2018 Mid-Year FCPA Update

-July 10, 2018

Trump Administration Revokes Primary Sanctions Relief Provided by the Iran Nuclear Agreement and Signals Strict Sanctions Enforcement

-July 2, 2018

Acting Associate AG Panuccio Highlights DOJ’s False Claims Act Enforcement Reform Efforts

-June 20, 2018

Revisions to the FFIEC BSA/AML Manual to Include the New CDD Regulation

-June 14, 2018

President Trump Issues Additional Sanctions Further Targeting PdVSA and the Government of Venezuela

-May 31, 2018

Update on Proposed Changes to the CFIUS Review Process

-May 30, 2018

The EU Responds to the U.S. Withdrawal from the Iran Deal

-May 21, 2018

The Trump Administration Pulls the Plug on the Iran Nuclear Agreement

-May 9, 2018

Webcast: Anti-Money Laundering and Sanctions Enforcement and Compliance in 2018 and Beyond

-May 4, 2018

FinCEN Issues FAQs on Customer Due Diligence Regulation

-April 23, 2018

Trump Administration Imposes Unprecedented Russia Sanctions

-April 12, 2018

United States Implements Increased Tariffs on Steel and Aluminum Imports: Exclusion Relief Possible

-March 23, 2018

Webcast: U.S. Economic and Trade Sanctions Against Venezuela – the Outlook for 2018

-March 15, 2018

2017 Year-End Sanctions Update

-February 6, 2018

U.S. and International Policy Convergence Brings Supply Chain Diligence on Labor Trafficking to the Fore

-November 30, 2017

Trump Administration Implements Congressionally Mandated Russia Sanctions – Significant Presidential Discretion Remains

-November 21, 2017

Cuba Sanctions: The Trump Administration Takes Steps to Implement Rollback of Obama Era Sanctions Relief

-November 16, 2017

Proposed Changes to the CFIUS Review Process

-November 10, 2017

Webcast: IPO and Public Company Readiness: Regulatory Compliance Issues

-November 1, 2017

Trump Decertifies the Iran Deal, Creating Both New Uncertainties and Potentially Unexpected Clarity

-October 16, 2017

In Latest Salvo, the Trump Administration Pressures Non-U.S. Companies and Persons to Cut Financial and Business Ties with North Korea

-September 26, 2017

Trump Administration Rescinds Deferred Action for Childhood Arrivals (DACA) Program

-September 5, 2017

President Trump Issues New Sanctions Targeting Certain Activities of PdVSA and the Government of Venezuela

-September 1, 2017

Congress Seeks to Force (and Tie) President’s Hand on Sanctions Through Passage of Significant New Law Codifying and Expanding U.S. Sanctions on Russia, North Korea, and Iran

-July 28, 2017

Update on Immigration Executive Order

-June 29, 2017

A Blockbuster Week in U.S. Sanctions

-June 19, 2017

Economic Sanctions Developments in the Early Trump Administration

-June 12, 2017

Competing Interests Weigh Against Broad Import Controls on Steel Imports After Section 232 Public Hearing

-June 9, 2017

Iran Sanctions Update – Status Quo So Far, Uncertainty Remains

-May 23, 2017

Court Orders Block Implementation of New Immigration Executive Order

-March 16, 2017

Analysis of March 6, 2017 Executive Order on Immigration

-March 7, 2017

Recent Developments in Counterfeiting

-February 24, 2017

Over Reliance on Sanctions Will Not Help Anyone’s Cause

-February 21, 2017

Ninth Circuit Court of Appeals Issues Opinion Upholding Nationwide TRO of January 27 Immigration-Related Executive Order

-February 10, 2017

Webcast: Tectonic Shifts in the Landscape of Economic Sanctions: Will the Pace of Change in 2016 Continue?

-February 8, 2017

2016 Year-End Sanctions Update

-February 6, 2017

New Sanctions Against Iran

-February 3, 2017

Recent Developments Regarding Executive Order on Immigration

-February 1, 2017

President Trump Issues Executive Order on Immigration

-January 30, 2017

2016 Year-End United Kingdom White Collar Crime Update

-January 11, 2017

President Obama Announces New Russian Sanctions in Response to Election-Related Hacking

-December 30, 2016

Trade Under Trump: How the New Administration Will Impact U.S. Economic Sanctions and Export Controls

-November 18, 2016

Cuba Sanctions Update – OFAC and BIS Announce Further Amendments to Cuba Sanctions Regulations

-November 4, 2016

Legal Implications of Expanded Use of Blockchain Technology

-November 1, 2016

DOJ’s New Guidance Urges Exporters to Self-Disclose Potential Export and Sanctions Violations

-October 28, 2016

Iran Sanctions Update – OFAC Issues Guidance Relating to Compliance and the Scope of Due Diligence for Non-U.S. Persons Engaging in Iran Transactions

-October 24, 2016

United States Lifts Burma (Myanmar) Sanctions in Response to Ongoing Democratic Reforms

-October 10, 2016

2016 Mid-Year United Kingdom White Collar Crime Update

-September 22, 2016

FinCEN Expands Temporary Reporting Requirements on Title Insurance Companies for All Cash Luxury Real Estate Transactions to Six Major U.S. Areas

-August 1, 2016

Beneficial Ownership and Customer Due Diligence:  Perspectives on the Increased Compliance Risk Associated with the Implementation of FinCEN’s Final Rule

-July 6, 2016

Key Issues for US Firms to Know about UK Decision to Brexit

-July 6, 2016

One Small Step or One Giant Leap? FAA Releases Final Rules on Commercial Drone Use in the United States

-June 27, 2016

OFAC Issues Additional Guidance on the Scope of Iran Sanctions Easement under JCPOA – Emphasizing the Limited Nature of the Present Relief

-June 16, 2016

Indonesia Update: New Negative Investment List

-June 6, 2016

Covered Investment

-June 1, 2016

The Directorate of Defense Trade Controls Changes Policy on Exports of Munitions to Vietnam Based on President Obama’s Announcement of Full Lifting of the Vietnam Arms Embargo

-May 26, 2016

United States Eases Myanmar (Burma) Sanctions in the Wake of Historic Democratic Reform

-May 20, 2016

United States Issues Regulations Authorizing Secondary Sanctions Against Non-U.S. Financial Institutions That Support Hizballah

-April 19, 2016

Webcast: Global Sanctions Update

-March 24, 2016

Do Not Pass Go, Do Not Collect $200: FinCEN Imposes Temporary Reporting Requirements on Title Insurance Companies for All Cash Luxury Real Estate Transactions in Manhattan and Miami

-February 11, 2016

United States Restricts Visa Waiver Travel

-February 4, 2016

2015 Year-End Sanctions Update

-February 2, 2016

Webcast – Challenges in Compliance and Corporate Governance – 2016

-January 20, 2016

“Implementation Day” Arrives: Substantial Easing of Iran Sanctions alongside Continued Limitations and Risks

-January 18, 2016

2015 Year-End False Claims Act Update

-January 6, 2016

2015 Year-End Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)

-January 5, 2016

2015 Year-End FCPA Update

-January 4, 2016

OFAC Issues General License Further Relaxing Burmese Sanctions

-December 10, 2015

Personal Liability for Senior Compliance Officers Under New York’s Proposed Anti-Money Laundering and Anti-Terrorism Regulation

-December 7, 2015

Serious Fraud Office v Standard Bank Plc: Deferred Prosecution Agreement

-December 3, 2015

Webcast: Blockchain Technology

-November 17, 2015

The 2015 Myanmar Elections: Impact on Myanmar Sanctions

-November 17, 2015

Webcast: The New Era of Fluid Global Sanctions

-October 21, 2015

“Adoption Day” Marks Next Step for Iran Nuclear Deal

-October 19, 2015

The Next Frontier in Sanctions Enforcement

-October 1, 2015

Bilateral and Multilateral Investments Treaties: What All Dealmakers Need to Know

-September 25, 2015

Iran Nuclear Deal Poised to Clear Political Hurdle in the United States

-September 2, 2015

2015 Mid-Year FCPA Update: Part 2

-August 31, 2015

2015 Mid-Year FCPA Update: Part 1

-August 17, 2015

Landmark Nuclear Agreement with Iran Reached

-July 14, 2015

2015 Mid-Year Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)

-July 8, 2015

2015 Mid-Year False Claims Act Update

-July 8, 2015

2015 Mid-Year FCPA Update

-July 6, 2015

A Dealmaker’s Guide to National Security Implications of Foreign Investment in U.S. Government Contractors

-June 30, 2015

Deadline Extended for All New Filers of the Commerce Department’s 2014 Benchmark Survey of U.S. Direct Investment Abroad (BE-10)

-May 29, 2015

Virtual Currency Regulation and Enforcement: Granting of First NY Charter and FinCEN Fine Demonstrate Continued Evolution for Virtual Currency Sector

-May 27, 2015

Guidelines for Reporting Under Commerce Department’s Benchmark Survey of U.S. Direct Investment Abroad (BE-10)

-May 8, 2015

US Government Implements Historic Changes to Cuba Sanctions Regime

-April 30, 2015

Cybersecurity Sanctions: A Powerful New Tool

-April 2, 2015

Blockchain Technology and Legal Implications of ‘Crypto 2.0’

-March 31, 2015

Webcast: Global Sanctions Update

-March 17, 2015

Webcast: Virtual Currencies

-March 10, 2015

Venezuela’s Currency Regulations May Violate Investment Treaty Protections

-February 25, 2015

U.S. Department of State Releases List of Cuban Goods and Services Now Eligible for Importation

-February 25, 2015

United States Drone Policy Stretches Its Wings

-February 23, 2015

Havana Calling: Easing the Embargo Will Open the Cuban Telecom Sector

-February 19, 2015

BitLicense 2.0: New York Moves Closer to Comprehensive Virtual Currency Regulation

-February 11, 2015

Webcast: Foreign Investments in Emerging Markets

-February 11, 2015