Trade Compliance
- Represented manufacturer of optical diagnostic devices in criminal investigation regarding possible FCPA violations and violations of the Iran sanctions program administered by OFAC. Led internal investigation and assisted client with production of documents in response to grand jury subpoena and OFAC subpoena, as well as interviews by Special Agents with the U.S. Department of Commerce, Bureau of Industry and Security – Office of Export Enforcement. Successfully negotiated the government investigation down to an OFAC administrative fine only, with no resulting criminal charges or fines.
- Represented global maritime industry group in OFAC investigation related to alleged violations of the Iranian Transactions and Sanctions Regulations in connection with port expenses and other trade-related transactions occurring at an Iranian port. Assisted client in responding to OFAC subpoena and conducted an internal investigation regarding the underlying Negotiated a favorable Settlement Agreement with OFAC for a reasonable administrative penalty and without any finding of fault or civil or criminal liability.
