Norton Rose Fulbright's International Trade and Sanctions team represents clients in all areas of United States, United Kingdom and European Union export, sanctions and anti-corruption laws and regulations as well as US Customs, CFIUS and anti-boycott matters.
This service encompasses lawyers across the firm's network of offices including Washington, D.C., New York, Houston, London, Hong Kong, Munich, Dubai and Riyadh.
We offer clients a seamless global response to multi-jurisdictional compliance issues, international trade and sanctions investigations, enforcement and litigation and have handled some of the most important compliance matters, regulatory investigations, enforcement proceedings and related litigation in this field.
Industries we have represented include aerospace, aviation, chemicals, cosmetics, defense, energy, financial services, higher education, insurance manufacturing, non-profit organizations, oil & gas, research & development, and technology.
Norton Rose Fulbright's specific experience includes:
- export and trade of dual use goods, software and technology: including under the US Department of Commerce, Bureau of Industry and Security ("BIS") Export Administration Regulations ("EAR"), the UK Export Control Organization and Her Majesty's Revenue and Customs
- export and trade of defense and aerospace goods, services and technical data: including under the US Department of State, Directorate of Defense Trade Controls ("DDTC") International Traffic in Arms Regulations ("ITAR"), the UK Export Control Organization and Her Majesty's Revenue and Customs
- economic sanctions and embargo regulations: including those administered by the US Department of Treasury, Office of Foreign Assets Control ("OFAC") as well as United Kingdom and European Union sanctions regulations
- anti-boycott regulations: including Department of Commerce and Department of Treasury anti-boycott regulations
- Committee on Foreign Investment in the United States ("CFIUS"): all aspects of CFIUS filings including section 721 of the Defense Production Act of 1950, as amended by the Foreign Investment and National Security Act of 2007 (FINSA) (section 721)
- anti-corruption regulations: including the Foreign Corrupt Practices Act ("FCPA") and the UK Bribery Act
- customs laws: including classification, valuation, origin, marking, preference programs and quotas, drawback and NAFTA regulations
- classification requests: drafting and submitting numerous classification requests to BIS
- commodity jurisdiction requests: drafting and submitting numerous commodity jurisdiction requests to DDTC
- export license applications: obtaining numerous export licenses from BIS, DDTC and OFAC
- compliance policies and procedures: extensive experience developing and implementing export, sanctions, anti-boycott and anti-corruption compliance policies and procedures
- pre- and post- acquisition due diligence: conducting pre- and post- acquisition export, sanctions and anti-corruption due diligence
- training presentations: training employees on all aspects of US and UK export, sanctions, anti-boycott and anti-corruption laws
- US Customs: significant experience drafting Customs petitions and obtaining US Customs rulings, responding to verification requests, determining origin and valuation, obtaining drawback and addressing quota and trade agreement issues
- CFIUS: extensive experience handling CFIUS filings involving a variety of industries
- internal audits and investigations: conducting worldwide export control, sanctions and anti-corruption internal audits and investigations
- government investigations and enforcement actions: responding to US and UK Government export, sanctions and anti-corruption investigations and enforcement actions including representation before the US
- Securities and Exchange Commission (SEC) and the US Department of Justice (DOJ)
- voluntary self-disclosure: counseling on the propriety of self-disclosures and drafting and submitting voluntary self-disclosures to BIS, OFAC, DDTC, DOJ and SEC