Rimon’s export control and economic sanctions attorneys advise clients on the ever-evolving international trade regulatory environment.  Our team, with backgrounds within government agencies, in-house, and private practice, advise on a range of issues including export controls, defense trade controls, economic sanctions, and antiboycott compliance. We advise clients on U.S. and international export control rules and economic sanctions, and are deeply familiar with the Export Administrations Regulations (EAR), The International Traffic in Arms Regulations (ITAR), Office of Foreign Assets Controls (OFAC) , Foreign Trade Regulations (FTR) and the UN Security Council Resolutions (UNSCR). Our attorneys have also advised the WCO, the United Nations Security Council, EU Commission, European External Action Service (EEAS), the Federal Office for Economic Affairs and Export Control (BAFA) and countries including Saudi Arabia, China, UAE, Russia, Singapore and Morocco on export controls and sanctions law matters.

Selected Experience

• Counseled Asia-based multinational semiconductor and technology companies on compliance with the EAR including licensing requirements under de minimis and foreign direct product rules.
• Settled alleged export control and sanctions violations for a multinational corporation resulting in a mitigation of over $300 million in fines; successfully closed federal criminal investigations into trade related violations.
• Determined jurisdiction and classification under the EAR and the ITAR and obtained licenses for dual use export of goods, software, technologies and military products.
• Advised US and non-US companies doing business in Iran, Russia, China, North Korea, Syria, Sudan, and Cuba on compliance with UN, U.S. and other sanctions and export control laws; obtained UN exemptions, OFAC and BIS licenses for clients.
• Advised and represented US and non-US companies on navigating sanctions and export controls on Russia including delisting, licenses, and unblocking.
• Applied for OFAC unblocking requests and specific licenses for clients in the banking and telecommunication sectors, as well as prominent news media outlets and non-profits.
• Advised global news agencies, large Chinese ecommerce companies, multinational freight forwarders, and technology companies on U.S. extraterritorial sanctions, export control laws and compliance measures.
• Obtained UN Security Council sanctions exemptions for humanitarian aid organizations.
• Successfully represented clients under investigation by the Office of Export Enforcement (OEE), Homeland Security Investigations (HSI), and the Office of Foreign Assets Control (OFAC).
• Led national and international internal investigations for export control, sanctions, and anti-boycott violations resulting in voluntary disclosures to government agencies as well as developing remedial measures to improve internal corporate compliance.
• Advised and conducted due diligence for foreign companies contracting with large Russian companies and banks regarding US/EU sanctions.
• Advised a prominent, publicly traded defense and aerospace company on sanctions compliance regarding several third-party vendors and representatives.
• Counseled a multinational semiconductor company on the implications associated with Huawei entities appearing on the US Department of Commerce’s Entity List.
• Supported a US energy company with respect to sanctions matters impacting an EPC contract pertaining to the establishment of a methanol gas plant.
• Guided a multi-party consortium consisting of various Japanese business conglomerates on the application of US sanctions and export controls to their chemical engineering joint venture in Venezuela.
• Counseled a US government-affiliated financial institution on the impact a sanctioned counterparty would have on the closing conditions of a multi-million-dollar back-to-back loan guarantee.
• Guided a European water technology company on US withdrawal from the Joint Comprehensive Plan of Action and the application of restored sanctions on its projects with Iranian-state-affiliated entities.
• Advised an M&A buy-side party with respect to Iranian, Ukrainian, Syrian, and Cuban sanctions violations committed by a target technology company.
• Represented large non-US multinational companies before their major banking partners regarding sanctions risk issues.

Rimon Attorneys With Expertise in Export Controls and Economic Sanctions Include:

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  Ricardo A. Ampudia

  Litigation and Alternative Dispute Resolution, Arbitration and Mediation, International, White Collar and Government Investigations, International Trade and Customs Law, International Transactions

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  Stephanie De Giovanni

  Litigation and Alternative Dispute Resolution, Europe, Regulatory, Compliance & Corporate Governance, International Trade and Customs Law

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  Mi-Yong Kim

  CFIUS/National Security, Export Controls and Economic Sanctions, International, International Trade and Customs Law, Regulatory, Compliance & Corporate Governance