Fried Frank regularly counsels a broad range of US and international clients on economic sanctions matters, including application of programs administered by the Office of Foreign Assets Control (OFAC) and the European Union (EU). The economic sanctions landscape has become even more complex in recent years, with additional restrictions imposed by Congress, other Executive Branch agencies, and even local governments in the form of investment and divestment laws. Our work in this area has spanned most sectors of the global economy, including financial institutions and investment funds, aerospace and defense, energy, telecommunications, insurance, manufacturing, high technology, engineering and construction services, shipping, software, industrials, medical devices, and food and beverage.
We have deep experience assisting companies in developing and implementing international trade compliance programs based on the company’s operations and needs. Our lawyers regularly provide counseling and training on economic sanctions matters, combining legal and policy expertise with a real-world understanding of business realities and implications. We work with clients to structure transactions to comply with US and international trade control laws, and to obtain authorization from the regulatory agencies for export or other commercial activity when necessary. In particular, we have been successful in procuring licenses from OFAC for our clients to engage in transactions that were otherwise prohibited by applicable law.
We also assist clients in responding to potential economic sanctions violations. Our team is experienced in conducting internal investigations of economic sanctions matters, as well as other related trade-related regulatory issues. Where appropriate, we assist clients in preparing voluntary self-disclosures to OFAC, as well as responding to government inquiries and civil and criminal enforcement actions.