• Sanctions Compliance Program design (following the U.S. Department of the Treasury’s “A Framework for OFAC Compliance Commitments”)

• Product and Technology Classification: Collaborate with clients’ technical experts to classify goods and technology under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). If necessary, submit commodity jurisdiction (CJ) requests to the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and commodity classification requests (CCATS) to the Bureau of Industry and Security (BIS).

• Advise clients regarding economic trade sanction risks and help obtain specific licenses from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).

• Conduct privileged, internal investigations following suspected export control or trade sanctions violations and perform Voluntary Self-Disclosure (VSD) analysis. Recommend remediation if export control or trade sanctions violations are suspected or confirmed.

The United States and other nations impose economic trade sanctions and enforce export control laws to promote foreign policy and national security goals. The U.S. for example restricts exports of certain goods and technology to many countries and prohibits dealing with numerous entities and individuals, many of whom are identified on sanctions lists, including but not limited to the Specially Designated Nationals List (SDN), the Sectoral Sanctions Identifications (SSI) List, the Denied Persons List, and the AECA Debarred List. Because prohibited transactions vary by program, sanctions laws and lists frequently change, and compliance is expected immediately, clients come to us for prompt, specific advice on navigating this complex area of the law full of traps for the unwary.