Representative Sanctions & Export Control Matters

Advising one of the world's largest integrated energy companies on complex US, EU, and UK sanctions and export controls governing the global sale and purchase of petroleum products. Scope includes:

• Conducting sanctions and export controls compliance assessments for operations in high-risk jurisdictions.
• Drafting urgent license application requests and corresponding with OFAC representatives to expedite license approvals.
• Reviewing financing agreements to ensure compliance with existing sanctions-related representations, warranties, and covenants.

Representing a major Brazilian multinational corporation in connection with contemplated purchases and sales of items subject to applicable US, EU, and UK sanctions and export control frameworks. Scope includes:

• Providing urgent compliance advice in relation to transactions involving sanctioned mines, vessels, and persons.
• Drafting contractual protections, including "Sanctions Event" triggers and termination rights within multi-jurisdictional transactional documents.
• Strategic scenario planning in relation to contemplated exports in high-risk jurisdictions.

Advising a major Latin American financial institution regarding OFAC and AML/CFT compliance in response to the US government's designation of regional drug cartels as Foreign Terrorist Organizations. Scope includes the creation of enhanced due diligence policies and procedures for high-risk accounts and cross-border payment flows.

Advising and assisting companies across a variety of industries in the creation and implementation of sanctions and export controls compliance policies and procedures, as well as conducting compliance uplifts for existing programs. Sectors include:

• Telecommunications and technology
• Agricultural commodities
• Energy and natural resources
• Maritime and shipping
• Pharmaceuticals and life sciences

Advising a US company in connection with the acquisition of a target engaged in Iran-related dealings involving products subject to the EAR.

Advising a US company in connection with an investigation concerning exports to Syria prior to the availability of License Exception SPP.

Developing a comprehensive sanctions and export controls compliance presentation and customer due diligence questionnaire for a data center company. Scope includes:

• Preparing a compliance presentation addressing applicable US (EAR/OFAC), EU, and UK sanctions and export controls obligations relevant to the data center sector.
• Drafting a customer due diligence questionnaire covering the end-use and end-users of equipment components, including advanced computing hardware and related technology.
• Identifying red flags and risk indicators associated with high-risk customers, jurisdictions, and end-uses.
• Advising on enhanced due diligence procedures for customers and transactions presenting elevated compliance risk.

Assisting a major gaming company with export control compliance and Outbound Investment Rule assessment.

Enforcement, Investigations & Voluntary Self-Disclosures

Advising an EU company on the assessment of an acquisition target's Voluntary Self-Disclosure (VSD) and the implementation of remedial actions.

Assisting a cybersecurity and technology company in preparing a VSD.

Representing a major software company in connection with small and medium-sized white-collar investigations.

Investment Treaty Arbitration

Canadian Mining Company — ICSID Arbitration (Romania BITs) Represented a Canadian mining company in a multi-billion-dollar ICSID arbitration under Romania's bilateral investment treaties (BITs) with Canada and the United Kingdom.

Republic of Bulgaria — ICSID Arbitrations (Energy Charter Treaty) Represented the Republic of Bulgaria in two ICSID arbitrations under the Energy Charter Treaty concerning electricity regulations.

Republic of Bulgaria — ICSID Arbitration (Bulgaria-Israel BIT) Defended the Republic of Bulgaria in an ICSID arbitration under the Bulgaria-Israel BIT relating to a real estate development project.

Kuwaiti Logistics Company — ICSID Arbitration (Iraq-Kuwait BIT) Represented a Kuwaiti logistics company in an ICSID arbitration under the Iraq-Kuwait BIT relating to a telecommunications license concession.

Italian Construction Company — ICSID Arbitration (Italy-Panama BIT) Represented an Italian construction company in an ICSID arbitration arising under the Italy-Panama BIT concerning the Panama Canal expansion project.

Advised several multi-national companies on how to structure their investments for optimal investment treaty protections, particularly in the APAC market.

Pro Bono

Amicus Curiae — U.S. Supreme Court (Barnes v. Felix) Led a team of attorneys in filing an amicus brief on behalf of AJI client National Police Accountability Project in support of the Petitioners before the United States Supreme Court. The Court unanimously vacated and remanded a Fifth Circuit decision on qualified immunity.

Amicus Curiae — 11th Circuit Court of Appeals (Martin v. United States) Appeared as amicus curiae before the United States Court of Appeals for the Eleventh Circuit in a case concerning the invalid execution of a no-knock warrant by law enforcement officers.

Special Immigrant Juvenile Status — Superior Court of the District of Columbia Represented a pro bono client in proceedings before the Superior Court of the District of Columbia, in collaboration with the DC Volunteer Lawyers Project (DCVLP). Drafted a third-party custody complaint and a motion for factual findings of eligibility for Special Immigrant Juvenile Status (SIJS). Successfully obtained SIJS status for the client.

Cross-Border Human Trafficking — Settlement Represented a pro bono client in a cross-border human trafficking matter and successfully obtained a settlement on the client's behalf.

Non-Unanimous Jury Verdicts — Louisiana Fourteenth Judicial District Court (Pro Hac Vice) Represented a client in connection with a non-unanimous jury verdict proceeding before Louisiana's Fourteenth Judicial District Court, appearing pro hac vice.