Steptoe handles all aspects of US and EU economic sanctions counseling, including advising multinational clients on compliance with comprehensive sanctions targeting Crimea, Cuba, Iran, North Korea, and Syria as well as increasingly complex rules concerning Russia, Ukraine, Venezuela, and the List of Specially Designated Nationals (SDNs) and Blocked Persons administered by the US Office of Foreign Assets Controls (OFAC). We frequently interact with the US Government, as well as the competent sanctions authorities in Europe and at the United Nations. Whether your organization is building its first sanctions compliance program or undertaking a high-stakes investigation or defense strategy, Steptoe’s team of seasoned experts stands ready to assist around the clock from offices in North America, Europe, and Asia.
We have particular experience in:
- International Compliance: With offices in key regulatory hubs beyond Washington, DC, such as Beijing, Hong Kong, London, and Brussels, Steptoe specializes in advising non-US clients on how US sanctions laws and regulations apply to their multinational business activities. We have assisted leading international financial institutions and corporates around the globe in developing risk-based compliance programs, conducting internal investigations of potential breaches, and navigating the complexities of cross-border enforcement cases involving authorities in the United States, China, Hong Kong, the European Union, the UK, and other jurisdictions.
- Investigations & Enforcement: Steptoe has extensive experience in handling sanctions investigations, including investigating and remediating breaches of corporate compliance controls, responding to governmental information requests, subpoenas, pre-penalty contacts, negotiated settlements, and administrative and criminal enforcement proceedings, as well as advising clients on their decision making about voluntary self-disclosures and stakeholder communications. We have also assisted several clients, from individuals to multinational companies, in seeking removal from the SDN List and the US government’s various other lists of restricted parties.
- 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. Examples of our work include (but are not limited to) providing extensive counseling with respect to clients impacted by changes to the Iran sanctions program, preparing detailed analysis and legal strategy on behalf of clients exposed to sanctions under OFAC’s Russia/Ukraine, Cuba, Iran, North Korea, Syria, and Venezuela-related sanctions programs; counseling clients on the designation of Russian, Ukrainian, Iranian, and Chinese blocked persons (among others) and their ownership interests in major corporations; advising on the scope and impact of the Sectoral Sanctions Identification List and Crimean embargo; and assisting clients in managing the winding down or continuation of business pursuant to general licenses under various OFAC programs.
- 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. Our team includes lawyers who have hands-on experience working in-house on legal and compliance teams in multinational companies based around the world.
Click here to learn more about our Economic Sanctions practice.
Steptoe’s export controls practice spans the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (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 clients in the manufacturing, defense, and trading sectors depend on us for sophisticated guidance on managing complex export control regimes and supply-chain risks around the globe.
We have particular experience in:
- International Compliance: 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 a variety of 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.
- Advanced Technologies and Encryption: Our team actively monitors and advises clients on amendments to the EAR and forthcoming controls targeting emerging and foundational technologies, including robotics, artificial intelligence, biotechnology, telecommunications, and other high technologies. Our specialist lawyers routinely advise clients on difficult questions about the application of export controls to the latest software, encryption technology, and controlled data, which have a significant impact on financial services and other industries.
- Anti-Boycott: We provide a range of counseling, compliance, investigation, and remedial services, covering anti-boycott provisions under the EAR and the Treasury Department Anti-Boycott Guidelines issued under Section 999 of the Internal Revenue Code. We offer legal advice/opinion services related to interpretation of regulatory requirements and have experience advocating interpretive and policy positions with US government officials responsible for the interpretation and enforcement of the anti-boycott rules.
Click here to learn more about our Export Controls practice.
Click here to learn more about our Anti-Boycott practice.