Export Controls, Economic Sanctions, and Antiboycott Rules
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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 conducts internal investigations in this area and has successfully defended clients in enforcement proceedings.
- 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.