Sanctions, Export Controls and Compliance

Clients operating in the global market place must navigate a complex web of international trade and financial compliance requirements administered by various arms of the U.S. Government, such as the Treasury Department, the State Department’s Directorate of Defense Controls, and the Committee on Foreign Investment in the U.S. Clients need counsel who understand economic sanctions and national security licensing restrictions, and related areas, such as the Foreign Corrupt Practices Act, other anti-corruption criminal laws, and international human rights obligations.

Financial institutions, government contractors, multinational corporations, and state-owned entities, have been attracted by Jason Wright’s military service, international experience, top secret security clearance, and diverse national security and human rights experience.

Recent Matters

• Represented a Southeast Asian financial institution in defense of an investigation conducted by Homeland Security Investigations relating to economic sanctions.
• Advised a board member from a Middle Eastern financial institution on matters pertaining to a Department of Justice investigation, a Treasury Specially Designated Nationals (SDN) designation, and sanctions imposed by the Office of Foreign Assets Control (OFAC).
• Advised a corporate defense contractor on a technology transfer issue with a foreign government requiring an analysis under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR).
• Drafted a civil complaint for a foreign government to prevent U.S.-based fundraising by a 501(c)(3) organization that supported foreign paramilitary activities in violation of the Neutrality Act, 18 U.S.C. § 960, and the Internal Revenue Code.
• Represented a multinational corporation to serve as lead litigation counsel in defending investigations conducted by the Treasury Department and the Department of Homeland Security.