Steptoe handles all aspects of US and EU economic sanctions counseling, including the most recent Russia/Ukraine/Crimea sanctions and rapid developments concerning Iran, Syria, Cuba, and Myanmar. We frequently interact with the US Government, as well as the competent authorities in Europe. We have particular experience in:
- Investigations & Enforcement: Steptoe has extensive experience in handling sanctions investigations, including information requests, subpoenas, pre-penalty contacts, negotiated settlements, and administrative and criminal enforcement proceedings.
- Counseling & Licensing: We counsel clients on the meaning and practical application of all US and EU-related sanctions laws and regulations, as well as assist in the submission of license or guidance requests to relevant regulatory authorities. With regard to specific country or list-based programs, in addition to extensive work under the Iran sanctions program, we provide detailed analysis under the Ukraine-related sanctions programs; counsel clients on the designation of Russian and Ukrainian blocked persons and their ownership interests; advise on the scope and impact of the Sectoral Sanctions Identification List; and advise on the comprehensive sanctions targeting Crimea. Recently, we have counseled clients on the liberalization of the Cuban embargo.
- Internal Compliance & Due Diligence: Steptoe works closely with clients to develop a tailored, workable, and practical sanctions compliance program by understanding the nature of a company’s operations and its internal organizational and functional structure, in order to assess risks and vulnerabilities and provide workable compliance solutions.
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Steptoe’s export controls practice spans the ITAR, the EAR, and the Department of Energy Part 810 and Nuclear Regulatory Commission Part 110 regimes. We handle licensing and advisory matters under EU dual-use and military export controls, including the EU Dual-Use Regulation and member state implementing legislation.
Our cross-border team consists of experienced export control attorneys in the US and EU that frequently develop, implement, and assess export compliance programs for US and non-US clients, and provide analyses of regulatory requirements as they are applied to business lines. Our team has handled hundreds of internal investigations, voluntary and mandatory disclosures to regulatory agencies where necessary, and civil and criminal enforcement actions initiated by regulatory and law enforcement officials in the US and EU countries. Our team also has extensive experience with various aspects of Export Control Reform, including new commodity jurisdiction and classification, use of licensing exemptions, and key definitions.
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International Regulation & Compliance
Steptoe’s Economic Sanctions and Export Controls practices are part of Steptoe’s larger International Regulatory Compliance Group. Our global team counsels clients on the scope, meaning, administration, and enforcement of cross-border regulations that affect international business transactions. In addition to economic sanctions and export controls work, we cover the full panoply of regulatory requirements, including: