Sanctions & Export Controls

Compliance, Licensing, and Litigation Defense Across All Regulatory Facets of International Trade

Expot ControlsNavigating sanctions and trade regulations can be overwhelming for businesses of all sizes.  Whether you are selling export-controlled goods, seeking an OFAC or BIS license to export commodities, or require defense in a criminal or civil enforcement matters, or removal from the BIS Entity List or the OFAC SDN List, Akrivis Law Group, PLLC can help you at every step.  We move beyond just providing advice, also offering solutions with an eye to the long term.  The firm represents clients ranging from public companies to small businesses and individuals, and customizes its approach to match the needs and budgets of these varied clients on pressing issues.

Our trade practice covers compliance and defense matters related to the following areas:

  • U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)
  • U.S. Department of Commerce’s Bureau of Industry & Security (BIS) Export Administration Regulations (EAR)
  • U.S. Customs and Border Protection (CBP)
  • Foreign Corrupt Practices Act (FCPA)/Anti-Corruption
  • Committee on Foreign Investment in the United States (CFIUS) Filings/Disclosures and Compliance
  • International Traffic in Arms Regulations (ITAR)
  • Anti-Boycott Compliance
  • Civil and criminal enforcement of sanctions violations, including white collar defense and litigation

Sanctions & Export Controls Practice – Compliance Advisory, Licensing, Civil & Criminal Defense, and Delisting

With respect to U.S. sanctions, Akrivis maintains one of the United States’ preeminent practices in the field, bringing unique insight into this area stemming from our exceptionally large caseload, along with extensive experience gained by our partners on sanctions matters while working in some of the world’s largest, most prestigious law firms.  With sanctions regulations changing on an almost weekly basis, our vast experience in this area as well as international business law will be particularly helpful for those companies seeking to ensure full compliance with U.S. law.

Our lawyers regularly advise a broad spectrum of clients around the world on sanctions compliance and defense, an area of increasing importance due to its significant relationship with U.S. national security.  Our finger is on the pulse of this ever-changing area of law and we represent clients large and small before OFAC regularly.  Partner Farhad Alavi speaks internationally on U.S. sanctions matters, appearing regularly on international media such as the BBC, Al Jazeera and CGTN, and is often quoted in major media outlets such as The New York TimesLos Angeles TimesFinancial Times (London), Washington Post, and the Wall Street Journal.

Whether your issues relate to the regulations administered by OFAC or the BIS, Akrivis Law Group, PLLC is well-positioned to help you meet your compliance and enforcement needs, such as:

  • Obtaining OFAC licenses for transactions in or involving sanctioned countries and entities
  • Civil Sanctions Enforcement Issues and Voluntary Self-Disclosures (VSDs)
  • Criminal Defense Arising from alleged IEEPA / Sanctions and Export Control Violations
  • Removal from OFAC’s List of Specially Designated Nationals and Blocked Persons (the SDN List)
  • Developing Internal Corporate and Organizational Trade Compliance Programs
  • Release of Blocked Funds at U.S. Financial Institutions
  • International Funds Transfer/ Bankwire and Anti-Money Laundering-related issues

Beyond compliance, we can represent clients on all facets of civil and criminal enforcement, including complete solutions on white collar, sanctions defense and internal corporate investigations arising from alleged sanctions violations.

Complementing our OFAC and BIS practice, we can also advise on exports falling under the jurisdiction of the ITAR and apply for licenses from the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC).

The BIS maintains stringent requirements on the actual and deemed export of U.S.-controlled “dual use” goods and information around the world.  This can affect all types of businesses, from startups exporting a controlled good to established public companies.  We regularly represent clients seeking Commodity Classifications, filing Voluntary Self-Disclosures, applying for Export Licenses, handling issues related to listings on the BIS Entity List and Unverified List such as removal, as well as on developing compliance programs designed to prevent future mishaps and mitigate penalties.

Customs Regulations

For those with inbound trade issues ranging from tariff rate quotas (TRQ) to Harmonized Tariff Schedule (HTS) classifications to outbound and inbound enforcement such as seizures, effective counseling on Customs can make the difference between whether your business moves forward smoothly and boldly or whether your goods get stuck in the ports.  Our experience spans an array of critical issues ranging from CBP seizing goods, to determining the appropriate Customs HTS classification and TRQs for a given good.

Foreign Corrupt Practices Act (FCPA) 

Compliance with anti-corruption laws is a keystone for doing effective business overseas. With increasing overseas business opportunities and the expansion of OECD and other directives against corruption, anti-corruption is no longer simply an issue of corporate social responsibility but a legal obligation.  This is heightened by intensifying enforcement of FCPA by the U.S. Department of Justice (DOJ).  Our FCPA and Anti-Corruption practice regularly advises U.S. and overseas clients on their FCPA obligations from advisory work to compliance.  We can also advise and represent clients on all facets of an FCPA criminal defense matter, including conducting internal investigations and bolstering compliance procedures.

U.S. Anti-Boycott Laws

The United States maintains stringent laws preventing the use of its companies as instruments in furthering economic boycotts in other countries. The most significant boycott is the Arab League’s boycott of Israel. Requirements can vary from situation to situation, and can often include reporting to the BIS. Akrivis can help you determine what issues are of relevance to you and how to ensure compliance