Export Controls, Economic Sanctions, and Antiboycott Rules

HWG counsels companies regarding compliance with U.S. and multilateral economic sanctions and export controls and represents them before a variety of agencies to obtain licenses necessary to consummate investment, financial, and export transactions.

These agencies include: the Department of the Treasury’s Office of Foreign Assets Control (OFAC); the Department of Commerce’s Bureau of Industry and Security (BIS); the Department of State’s Directorate of Defense Trade Controls (DDTC), Office of Terrorism Finance and Sanctions Policy, and regional bureaus; and the Department of Defense Security Service (DSS) and Defense Information Systems Agency (DISA). We also conduct internal investigations in this area and have successfully defended clients in enforcement proceedings.

Representative Matters

• Advised large international services companies on policies, procedures, and monitoring to ensure compliance with export controls and economic sanctions.
• Forcefully challenged charges of export control violations, avoiding major penalties and achieving a policy reversal that removed a regulatory bar to the client’s core business.
• Obtained the fastest-ever waiver of statutory bar on infrastructure projects with any Iranian involvement and obtained timely OFAC license.
• Conducted a major transnational internal investigation of potential trade control violations for a public company’s audit committee, and orchestrated voluntary self-disclosures to OFAC and BIS with very favorable results.
• Represented infrastructure provider in obtaining an OFAC license permitting an infrastructure project in Sudan, including a successful appeal before the interagency Operating Committee chaired by BIS.
• Successfully represented project developer in interagency process to obtain an export license to construct a chemical plant in the Middle East, where initial license application had been denied prior to engagement of HWG.
• Successfully represented non-governmental organization in obtaining OFAC licenses to conduct scientific and educational activities in Cuba.

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