Recent successful matters include
- Partner David Ring completed his service as a DDTC-appointed Special Compliance Official for Esterline Technologies, which successfully completed its consent agreement in three and one-half years—a near-record pace for recent consent agreements.
- Partner Tahlia Townsend worked with a Fortune 200 company with operations in every corner of the world, to implement a global rollout of a sanctions compliance program, including global training materials, denied-party screening procedures, a process for compliant use of General License H, and processes for compliant use of general licenses related to agricultural and medical products. At the same time, Tahlia conducted a multi-continent, multi-vertical, global investigation into the past practices of the company's non-U.S. subsidiaries as part of her efforts to protect the company from OFAC penalties. Consistent with her work for this client, Tahlia frequently provides sanctions advice to U.S. and non-U.S. clients alike, including to law firms around the world.
- Immediately after federal agents raided the U.S. headquarters of a private billion-dollar company for reasons relating to trade sanctions, the company called partners Tahlia Townsend and David Ring to handle the criminal case and help quickly upgrade their compliance program. Our team moved expeditiously to shut down publication of the sealed search warrant application, which apparently was leaked by law enforcement to an internationally syndicated journalist; complete an exhaustive internal investigation; and then obtain a written declination from the U.S. Department of Justice and the promise of zero monetary penalties from BIS. At the same time, we helped implement a best-in-class sanctions screening program and obtained favorable CCATS determinations that allowed the company to reclassify many of its product lines.
- Dan Goren, Counsel at the firm, has emerged as a go-to subject matter expert on export controls for encryption commodities—one of the most difficult areas of U.S. export law. Over the past year, Dan has helped numerous companies, both in the U.S. and abroad, classify their encryption products and navigate the thicket of reporting requirements often associated with the regulation of these goods. Dan recently was tapped by a Fortune 50 defense contractor to help construct a process for classifying encryption items under the EAR.
- Partner Dave Hall—whose past exploits as one of the nation's top federal prosecutors for export control cases have been featured in top-selling books and numerous televised documentaries—recently testified before the Subcommittee on the Western Hemisphere of the U.S. House of Representatives' Committee on Foreign Affairs, on "Examining the Effectiveness of the Kingpin Designation Act in the Western Hemisphere." Dave persuasively advocated the abolition of OFAC's "Fifty Percent Rule" and the creation of a good-faith exception to the strict liability standard. His testimony emphasized the inequity and inefficiency of the government's outsourcing of the process for identifying sanctioned-party determinations to private industry, while creating grave risks for those companies that don't perform this essentially governmental function well.
- Partners Jim Glasser and Tahlia Townsend and Counsel Dan Goren were retained by one of the world's largest banks to review hundreds of international transactions and guide the bank through the process of disclosing, as necessary, to OFAC.
- Partner Tahlia Townsend and Counsel Dan Goren are entering their fifth year teaching a course on international trade compliance law at the University of Connecticut School of Law, one of the few graduate-level courses of its kind. The course introduces students to the fundamentals of international trade compliance law, including the complex U.S. regulations controlling exports and imports; U.S. anti-boycott laws; and U.S. economic sanctions. As a testament to the success of the course, a growing number of the school's graduates have found trade compliance positions with major U.S. corporations impressed with their fluency with the regulations and practical insights derived from Dan and Tahlia's scenario-based teaching.