Global Trade & Sanctions

In the face of increasingly complex international trade and national security regulation issues, our Global Trade & Sanctions team equips clients for success. We deliver comprehensive guidance involving U.S. economic sanctions, export controls, customs compliance, foreign investment reviews, and related regulatory frameworks, positioning clients to effectively manage risk, maintain compliance, and achieve commercial goals across borders.

From day-to-day operations and internal governance to cross-border transactions, supply chain planning, and regulatory advocacy, we support clients through all stages of compliance. Our advice is calibrated to today’s dynamic global environment, where changing U.S. trade policies, enforcement priorities, and national security concerns often dictate how, where, and with whom businesses can operate.

Key Areas of Focus

Export Controls

We counsel on the export of goods, software, and technology under the International Traffic in Arms Regulations (“ITAR”), Export Administration Regulations (“EAR”), Department of Energy Part 810, and U.S. anti-boycott laws. Our support includes jurisdiction and classification determinations, license preparation, use of license exceptions, ITAR registration, compliance program design, and enforcement defense.

Import and Customs Compliance

We represent importers before U.S. Customs and Border Protection and other federal agencies. Our services cover tariff strategy, antidumping and countervailing duty (“AD/CVD”) matters, classification and valuation, country-of-origin analyses, ruling requests, prior disclosures, protest procedures, and supply chain risk assessments under the Uyghur Forced Labor Prevention Act (“UFLPA”).

Tariff Advisement

We strategically guide clients through the shifting terrain of U.S. tariff policy, including Section 301 duties on China-origin goods, Section 232 tariffs on steel and aluminum, and country-specific retaliatory measures. Our team advises on exclusion opportunities, post-summary corrections, tariff engineering strategies, and the use of preferential trade programs such as USMCA, GSP, and others to reduce landed cost and avoid unnecessary duty exposure.

HTS and Country-of-Origin Analysis

We assist companies in optimizing their global sourcing and manufacturing strategies by conducting proactive reviews of Harmonized Tariff Schedule (“HTS”) classifications and country-of-origin determinations. Our legal and strategic advisement enables clients to align their supply chain structures with tariff minimization goals, meet eligibility for free trade agreements, and reduce the risk of enforcement related to misclassification, undervaluation, or incorrect origin declarations. We routinely coordinate with engineering, sourcing, and logistics teams to ensure technical accuracy and regulatory defensibility.

Economic Sanctions

We advise on economic sanctions administered by the Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State. Our work includes sanctions screening protocols, risk reviews, licensing strategies, use of exemptions and general licenses, program development, and petitions for delisting from restricted party lists, such as the Specially Designated Nationals (“SDN”) List.

BSA/AML Compliance

We support clients in implementing and enhancing anti-money laundering (“AML”) and Bank Secrecy Act (“BSA”) programs, including for financial institutions and fintech platforms. Our work spans policy drafting, independent reviews, transaction monitoring analysis, suspicious activity escalation, and regulatory examination response.

Anti-Corruption and the FCPA

We advise on the Foreign Corrupt Practices Act (“FCPA”) and related global anti-bribery laws. Our services include program development, internal investigations, risk mitigation, and representation in DOJ and SEC inquiries.

CFIUS and Foreign Investment Controls

We assist in analyzing whether a transaction involving non-U.S. investors may fall under the jurisdiction of the Committee on Foreign Investment in the United States (“CFIUS”). Our team provides end-to-end support — from risk assessments and filing strategy to negotiating national security agreements and engaging with relevant agencies throughout the review process.

Outbound Investment Reviews

We counsel clients on the new regulatory framework governing outbound investment in sensitive sectors, particularly with respect to advanced technologies and U.S. adversary jurisdictions such as China. We help assess whether proposed investments are covered by current or emerging Treasury Department restrictions.

ICTS and Supply Chain Security

We guide companies through the Commerce Department’s regulations governing Information and Communications Technology and Services (“ICTS”) transactions that may pose national security concerns. Our support includes compliance evaluations, mitigation strategies, and engagement with the U.S. government regarding supply chain vulnerabilities tied to foreign jurisdictions.