Jeff is a senior associate with the International Trade & Regulatory Group in the firm’s Washington, D.C., office. Jeff counsels clients on the regulation of cross-border transactions, with a particular focus on U.S. export controls and sanctions, including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR) and the economic sanctions administered by the Office of Foreign Assets Control (OFAC). Jeff also advises clients involved in foreign acquisitions of U.S. businesses before the Committee on Foreign Investment in the United States (CFIUS) and, for U.S. businesses operating under a security clearance, Jeff helps clients resolve foreign ownership issues under the National Industry Security Program Operating Manual (NISPOM).
On the import side, Jeff advises clients on customs issues and preferential trade programs (e.g., NAFTA, DR-CAFTA, GSP) and represents importers in disputes with the United States before the Court of International Trade and the Court of Appeals for the Federal Circuit.
Prior to attending law school, Jeff worked as a strategy consultant in the Washington, D.C., office, of Kaiser Associates, Inc., where he advised industry-leading clients on a variety of corporate strategy issues, including market analysis and market entry, product launch and global supply chain strategy.
- Extensive guidance on U.S. export controls compliance to the aerospace, pharmaceutical, chemicals, automotive, software, consumer products, scientific research, military vehicle and electronics industries, both domestic and foreign.
- Representation of companies in commodity jurisdiction requests before DDTC and commodity classification rulings before BIS, including “escalated” inter-agency jurisdiction determinations.
- Representation of exporters in connection with BIS, DDTC and DOJ subpoenas, investigations and criminal and administrative enforcement settlement negotiations.
- Internal investigations and voluntary disclosures of violations of U.S. export control and sanctions regulations and development of corrective actions.
- Voluntary and government-mandated export compliance audits and drafting audit reports.
- Assistance to importers and exporters in creation and maintenance of compliance programs. This includes development and implementation of U.S. and global technology control strategies for sensitive data environments, including compliance with U.S. restrictions on access to classified and unclassified technical data, Foreign Ownership, Control and Influence (FOCI) issues and other technology control issues arising under the ITAR, BIS and National Industrial Security Program Operating Manual (NISPOM).
- Advice and implementation of advice concerning handling of routed exports.
- Guidance on the extraterritorial application of U.S. export control laws to foreign-manufactured goods, including de minimis U.S. content analyses.
- Obtaining BIS and OFAC licenses to export permissible goods (e.g., medical devices) to otherwise embargoed destinations.
- Prepare and submit export or transfer authorization requests on behalf of U.S. exporters and foreign re-exporters.
- Represent importers of graphic arts products in customs disputes before the U.S. Court of international Trade and the U.S. Court of Appeals for the Federal Circuit.
- Submit prior disclosures, ruling request letters, and classification protests to United States Bureau of Customs and Border Protection on behalf of importers of chemicals, metals, consumer products, and garments.
- Submit short supply and commercial availability ruling requests pursuant to DR-CAFTA on behalf of the U.S. importer of wool fabrics.
- Advise North American manufacturers on origin marking and “made in USA” regulations for products made of mixed origin components.
- Advise North American manufacturers of packaging materials on opportunities and incentives to develop or acquire manufacturing capabilities in Eastern Europe to facilitate exportation into the EU and Russia.
January 10, 2012
December 15, 2009
- Coalition for Excellence in Export Compliance (CEEC), an independent group of trade compliance professionals developing standards that reflect best practices in global export compliance.
- American Association of Exporters and Importers (AAEI); AAEI Export Control and Facilitation Committee.
- ABA International Section; International Trade, Export Controls and Economic Sanctions and Customs Law Subcommittees.
- Society of International Affairs (SIA).
- Washington International Trade Association (WITA).
- Capital Area Immigration Rights (CAIR) Coalition Litigation Advisory Board.